student financial assistance programs department of

April 2018 Student Financial Assistance Cluster

Compliance Supplement 5-3-1

STUDENT FINANCIAL ASSISTANCE PROGRAMS

Department of Education

Department of Health and Human Services

CFDA 84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY

GRANTS (FSEOG)

CFDA 84.033 FEDERAL WORK-STUDY PROGRAM

CFDA 84.038 FEDERAL PERKINS LOAN (FPL)—FEDERAL CAPITAL

CONTRIBUTIONS

CFDA 84.063 FEDERAL PELL GRANT PROGRAM

CFDA 84.268 FEDERAL DIRECT STUDENT LOANS

CFDA 84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND

HIGHER EDUCATION GRANTS (TEACH Grants)

CFDA 84.408 POSTSECONDARY EDUCATION SCHOLARSHIPS FOR

VETERAN’S DEPENDENTS (Iraq and Afghanistan Service Grant

(IASG))

CFDA 93.264 NURSE FACULTY LOAN PROGRAM (NFLP)

CFDA 93.342 HEALTH PROFESSIONS STUDENT LOANS, INCLUDING

PRIMARY CARE LOANS AND LOANS FOR DISADVANTAGED

STUDENTS (HPSL/PCL/LDS)

CFDA 93.364 NURSING STUDENT LOANS (NSL)

CFDA 93.925 SCHOLARSHIPS FOR HEALTH PROFESSIONS STUDENTS FROM

DISADVANTAGED BACKGROUNDS - SCHOLARSHIPS FOR

DISADVANTAGED STUDENTS (SDS)

I. PROGRAM OBJECTIVES

The objective of the student financial assistance programs is to provide financial assistance to

eligible students attending institutions of postsecondary education.

II. PROGRAM PROCEDURES

Institutions must apply to either the Secretary of Education or Secretary of Health and Human

Services to participate in their particular SFA programs. Some applications must be filed

annually, others upon initial entry and once approved, periodically thereafter. Institutions may

be approved to participate in only one program or a combination of programs. Institutions are

responsible for: (1) determining student eligibility; (2) verifying student data (when required);

(3) calculating, as required, the amount of financial aid a student can receive; (4) completing

and/or certifying parts of various loan applications and/or promissory notes; (5) drawing funds

from the Federal Government and disbursing or delivering SFA funds to students directly or by

crediting students’ accounts; (6) making borrowers aware of loan repayment responsibilities;

(7) submitting, as requested, data on borrowers listed on National Student Loan Data System

(NSLDS) roster; (8) returning funds to students, lenders and programs, as appropriate, if students

withdraw, drop out or are expelled from their course of study; (9) collecting SFA overpayments;

(10) establishing, maintaining and managing (including collecting loan repayments) a revolving



loan fund for applicable programs; and (11) reporting the use of funds. Institutions may contract

with third-party servicers to perform many of these functions.

Title IV Programs - General

The Title IV programs cited in this cluster that are administered by the Department of Education

(ED) (those with CFDAs beginning with 84) are authorized by Title IV of the Higher Education

Act of 1965, as amended (HEA), and collectively are referred to as the “Title IV programs.”

Because they are administered at the institutional level, the Federal Perkins Loan Program,

Federal Work-Study Program and Federal Supplemental Educational Opportunity Grant Program

are referred to collectively as the “campus-based programs.”

For Title IV programs, students complete a paper or electronic application (Free Application for

Federal Student Aid (FAFSA) (OMB No. 1845-0001) and send it to a central processor (a

contractor of ED that administers the Central Processing System). The central processor

provides Student Aid Reports (SARs) to applicants and provides Institutional Student

Information Records (ISIRs) to institutions. Among other things, the SAR contains the

applicant’s Expected Family Contribution (EFC). Students take their SARs to the institution (or

the institution uses the ISIR) to help determine student eligibility, award amounts, and

disbursements. (Note: The central processor is a service organization of ED, not of the schools.

Therefore, AU-C Section 402, Audit Considerations Relating to an Entity Using a Service

Organization, does not apply when auditing the schools.)

Federal Pell Grant (Pell) (CFDA 84.063)

The Federal Pell Grant program provides grants to students enrolled in eligible undergraduate

programs and certain eligible post-baccalaureate teacher certificate programs, and is intended to

provide a foundation of financial aid. The program is administered by ED and postsecondary

educational institutions. Maximum and minimum Pell grant awards are established by statute.

ED provides funds to the institution based on actual and estimated Pell expenditures.

Postsecondary Education Scholarships for Veteran’s Dependents

(Iraq and Afghanistan Service Grant (IASG)) (CFDA 84.408)

The Higher Educational Technical Corrections, Pub. L. No. 111-39, amended the HEA to allow

an eligible student whose parent or guardian died as a result of U.S. military service in Iraq or

Afghanistan after September 11, 2001, to receive this non-needs-based grant if he or she was not

receiving a Pell grant.

Federal Perkins Loan (FPL) (CFDA 84.038)

Health Professions Student Loans (HPSL)/Primary Care Loans (PCL)/Loans for

Disadvantaged Students (LDS) (CFDA 93.342)

Nursing Student Loans (NSL) (CFDA 93.364)

The FPL, HPSL/PCL/LDS and NSL programs provide long-term low-interest loans to students

who demonstrate the need for financial aid to pursue their course of study at postsecondary

educational institutions. Revolving loan funds are established and maintained at institutions

through applications to participate in the programs. The funds are started with the Federal



Capital Contribution (FCC) and a matching Institutional Capital Contribution (ICC).

Repayments of principal and interest, new FCC, and new ICC are deposited in the revolving

funds. The institution is fully responsible for administering the program (i.e., approving,

disbursing and collecting the loans). A borrower may have all or part of his or her Perkins loan

cancelled for qualifying employment as a teacher, as a law enforcement or corrections officer, or

in certain other public service occupations. A Perkins borrower also may receive loan

cancellation for eligible active duty military service and certain volunteer service. In addition,

Perkins loans may be discharged if the borrower becomes disabled, dies, or declares bankruptcy,

or the school which he or she attended closes. Primary Care Loans are a segment of

HPSL/PCL/LDS loan funds that impose certain restrictions on new borrowers as of July 1, 1993.

First-time recipients of these funds after July 1, 1993 must agree to enter and complete a

residency training program in primary health care, not later than 4 years after the date on which

the student graduates from medical school, and, for new loans issued after March 23, 2010, must

practice in such care for 10 years (including residency training in primary health care) or through

the date on which the loan is paid in full, whichever occurs first. Students who received their

first HPSL/PCL/LDS before July 1, 1993 are exempt from this requirement, and may continue to

borrow HPSL/PCL/LDS loans under their applicable health-related course of study.

Nurse Faculty Loan Program (NFLP) (CFDA 93.264)

The purpose of the Nurse Faculty Loan Program (NFLP), as authorized by Title VIII of the

Public Health Service Act (PHS Act), Section 846A, as amended by the Patient Protection and

Affordable Care Act of 2010, Pub. L. No. 111-148, Section 5311, is to increase the number of

qualified nursing faculty. The NFLP provides funding to schools of nursing to support the

establishment and operation of a distinct NFLP loan fund at the institution. The award to the

school, the FCC award, must be deposited into the NFLP loan fund. The school is required to

deposit the ICC that is equal to no less than one-ninth of the FCC award. Participating schools

make loans from the regular NFLP loan fund to eligible graduate (master’s and doctoral) nursing

students to complete the nursing education program. Accredited collegiate schools of nursing

are eligible to apply for funding. Eligible schools must offer an advanced education nursing

degree program(s) that will prepare the graduate student to teach. The institution is fully

responsible for administering the program (i.e., approving, disbursing, and collecting the loans).

All funds awarded for the specified budget or project period should be drawn down from the

Payment Management System (PMS) account and deposited in an appropriate loan fund. It is

expected that loan activity will be conducted though the institutional NFLP loan fund rather than

drawdowns from the PMS account.

Active NFLP grantees are permitted to maintain their loan fund balances in the revolving

institutional NFLP loan fund account without fiscal year restriction. The loan fund balance

should continue to be disbursed (expended) through the current budget or project period.

Program guidance is available at http://bhw.hrsa.gov/nursing/grants/nflp.html

http://bhw.hrsa.gov/nursing/grants/nflp.html



Federal Work-Study (FWS) (CFDA 84.033)

The FWS program provides part-time employment to eligible undergraduate and graduate

students who need the earnings to help meet costs of postsecondary education. This program

also authorizes the establishment of the Job Location and Development (JLD) program, the

purpose of which is to expand off-campus part-time or full-time employment opportunities for

all students, regardless of their financial need, who are enrolled in eligible institutions and to

encourage students to participate in community service activities. FWS recipients may also use

their funds for the Work-Colleges program, whose purpose is to recognize, encourage, and

promote the use of comprehensive work-learning programs as a valuable educational approach

when it is an integral part of the institution’s educational program and a part of a financial plan

that decreases reliance on grants and loans and to encourage students to participate in community

service activities (34 CFR section 675.43).

Funds are provided to institutions upon submission of an annual application, Fiscal Operations

Report and Application to Participate (FISAP) (OMB No. 1845-0030) (this application covers all

campus-based programs), and in accordance with statutory formulae. Institutions must provide

matching funds unless they are an eligible Title III or Title V institution, or unless the student is

employed in a position which is authorized for payment with 100 percent of Federal funds

(34 CFR section 675.26(d)). The institution determines the award amount, places the student in

a job, and pays the student or arranges to have the student paid by an off-campus employer. The

institution may use a portion of FWS funds for a JLD program.

Federal Supplemental Educational Opportunity Grants (FSEOG) (CFDA 84.007)

The FSEOG program provides grants to eligible undergraduate students. Priority is given to Pell

recipients who have the lowest expected family contributions. Federal funds are matched with

institutional funds (34 CFR section 676.21).

Teacher Education Assistance for College and Higher Education Grants (TEACH Grants)

(CFDA 84.379)

The TEACH Grant program is a non-need-based grant program for students who are enrolled in

an eligible program, and who agree to serve as a full-time teacher, in a high-need field, in a

school serving low-income students for at least 4 years within 8 years of completing the program

for which the TEACH Grant was awarded (34 CFR section 686.1). If the grant recipient fails to

complete the required teaching service, the TEACH Grant is treated as a Federal Direct

Unsubsidized Stafford Loan (Federal Direct Unsubsidized Loan) (34 CFR section 686.43).

Federal Direct Student Loans (Direct Loan) (CFDA 84.268)

(Includes subsidized Stafford, unsubsidized Stafford, and PLUS loans)

The Direct Loan program makes interest subsidized or unsubsidized Stafford loans available to

students, or PLUS loans to graduate or professional students or to parents of dependent students,

to pay for the cost of attending postsecondary educational institutions. Direct Loans are made by

the Secretary of Education. The student’s SAR or ISIR, along with other information, is used by



the institution to originate (for Direct Loan) a student’s loan. The financial aid administrator is

also required to provide and confirm certain information.

Under the Direct Loan program, institutions participate in loan origination Option 1, Option 2, or

Standard origination. Functions performed by loan origination option vary and are described in

the Direct Loan School Guide. Direct Loan is an electronic program, except that borrowers have

the option of signing paper promissory notes or electronically signing the promissory note

completed online. Except for electronically signed promissory notes, electronic records are

created, batched, transmitted (exported) through Common Origination and Disbursement (COD)

and acknowledged by (imported from) COD, on a cycle approach. A cycle is not complete until

the last activity in it is finished, i.e., an action has been accepted by COD and the school’s

system reflects the acceptance. Direct Loan has four types of cycles: Loan Origination Records

(one for each loan), Promissory Notes, Disbursement Records, and Change Records. For a loan

to be “booked” the institution must have electronically transmitted to COD, and COD must have

accepted these records: (1) the loan origination record; (2) the Promissory Note; and (3) the first

disbursement of loan proceeds. The borrower’s original accepted promissory note is maintained

at COD; the institution is not required to keep a copy.

Scholarships for Health Professions Students from Disadvantaged Backgrounds -

Scholarships for Disadvantaged Students (SDS) (CFDA 93.925)

The SDS program provides grants to eligible health professions and nursing schools to award

scholarships to financially needy full-time students from disadvantaged backgrounds who are

attending schools of medicine, osteopathic medicine, dentistry, nursing, pharmacy, podiatric

medicine, optometry, veterinary medicine, public health, chiropractic or allied health; schools

offering graduate programs in behavioral and mental health practice; or entities providing

programs for the training of physician assistants. For purposes of this program, HHS defines

disadvantaged as a student who (1) comes from an environment that has inhibited the individual

from obtaining the knowledge, skills, and abilities required to enroll in and graduate from a

health professions school, or from a program providing education or training in an allied health

profession; or (2) comes from a family with an annual income below a level based on low-

income thresholds according to family size published by the U.S. Bureau of the Census, adjusted

annually for changes in the Consumer Price Index, and adjusted by the Secretary of HHS for use

in health professions and nursing programs.

Submission of Financial Statement Information to ED

All institutions receiving grants or loans from ED under the specified Title IV programs are

required to input annual financial statement information to ED using eZ-Audit (OMB No. 1845-

0072). The eZ-Audit is the methodology used for reporting an institution’s financial statement

information. Registration instructions are available at

https://ezaudit.ed.gov/EZWebApp/common/login.jsp. Once an institution has registered,

additional guidance on how to input financial statement information is provided.

https://ezaudit.ed.gov/EZWebApp/common/login.jsp



Source of Governing Requirements

The ED programs are authorized by Title IV of the Higher Education Act (HEA) of 1965, as

amended (20 USC 1001 et seq.). The regulations are found in 34 CFR parts 600 and 668-690.

The HHS programs in this cluster are authorized by the Public Health Service Act (PHS Act).

The PHS Act was amended by the Health Professions Education Partnership Act of 1998,

Pub. L. No. 105-392 and, for the NFLP, further amended by the Patient Protection and

Affordable Care Act of 2010 (Affordable Care Act), Pub. L. No. 111-148, Section 5311.

Availability of Other Program Information

ED annually publishes the Federal Student Aid Handbook (FSA Handbook), which provides

detailed guidance on administering the Title IV programs. This handbook and other guidance

material are available at http://ifap.ed.gov/.

HHS publishes the Student Financial Aid Guidelines, which provide detailed guidance on

administering the Title VII and VIII programs. This and other materials are available at

http://bhpr.hrsa.gov/.

III. COMPLIANCE REQUIREMENTS

In developing the audit procedures to test for compliance with the requirements for the

SFA cluster, the auditor must determine, from the following summary (also included in

Part 2, “Matrix of Compliance Requirements”), which of the 12 types of compliance

requirements apply, and then determine which of the applicable requirements is likely to

have a direct and material effect on the SFA cluster at the auditee. For each such

requirement, the auditor must use Part 3 (which includes generic details about each

compliance requirement other than Special Tests and Provisions) and this cluster

supplement (which includes any cluster-specific requirements) to perform the audit.

Compliance Requirements

A B C E F G H I J L M N

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http://ifap.ed.gov/

http://bhpr.hrsa.gov/



Note: While the programs included in this cluster are generally similar in their intent,

administration and documentation, etc., there are differences among them. Because of space

considerations, this cluster supplement does not list all of the differences, exceptions to general

rules or nuances pertaining to specific programs. Auditors should use regulations and guidance

applicable to the year(s) being audited when auditing the SFA programs.

A. Activities Allowed or Unallowed

SFA funds can be awarded only to students enrolled in eligible programs. Eligible

programs are listed on an institution’s Eligibility and Certification Approval Report

(ECAR). Other programs can be added after the school’s most recent certification

without obtaining ED’s approval if they lead to an associate, baccalaureate, professional,

or graduate degree or are at least 8 semester hours, 12 quarter hours, or 600 clock hours,

and they prepare students for gainful employment in the same or a related occupation of a

previously ED-designated eligible program (34 CFR section 600.10(c)(2)).

SFA funds can be used for making awards to students, for administration of the

programs, and other allowable uses for specific programs as follows:

Federal Perkins Loan (CFDA 84.038)

Certain billing, collection, and litigation costs must first be charged to the borrower and

cannot be charged to the loan fund. If amounts recovered from the borrowers are not

sufficient to pay these collection costs, program funds can be used to pay these costs with

certain limits (34 CFR sections 674.8 and 674.47).

A school may transfer up to a total of 25 percent of its FCC for an award year to either or

both the FSEOG and FWS programs (34 CFR section 674.18(b)(1)). A school may

transfer up to 100 percent of its initial and supplemental allocations to an approved Work

Colleges program (34 CFR section 675.18(b)(2)). Transferred funds must be used

according to the requirements of the program to which they are transferred. A school that

transfers funds to the FWS, FSEOG, or Work Colleges programs must transfer any

unexpended funds back to the Federal Perkins Loan program at the end of the award year

(34 CFR section 674.18(b)(5)).

Federal Work-Study (CFDA 84.033)

The institution may use FWS funds only for awards to students, a Job Location and

Development (JLD) Program, Work-Colleges Program (as defined in 34 CFR section

675.41(a)), administrative costs, and transfers to FSEOG (34 CFR sections 675.18 and

675.33).

Federal Supplemental Educational Opportunity Grant (CFDA 84.007)

An institution may transfer up to 25 percent of its FSEOG financial allotment to the

institution’s FWS program (Section 488 of HEA (20 USC 1095)).



Health Professions Student Loans/Primary Care Loans /Loans for Disadvantaged

Students (CFDA 93.342) and Nursing Student Loans (NSL) (CFDA 93.364)

Funds from both programs may also be used for capital distribution in Sections 728 and

839, or, as agreed to by the Secretary of HHS for costs of litigation; costs associated with

membership in credit bureaus and, to the extent specifically approved by the Secretary,

for other collection costs that exceed the usual expenses incurred in the collection of loan

funds (HPSL/PCL/LDS, 42 CFR section 57.205(a); NSL, 42 CFR section 57.305(a)).


Funds may be used for capital distribution under Section 846A of the PHS Act, Title

VIII, as further amended by the Patient Protection and Affordable Care Act of 2010, Pub.

L. No. 111-148, Section 5311or, as agreed to by the Secretary of HHS for costs of

litigation; costs associated with membership in credit bureaus and, to the extent

specifically approved by the Secretary, for other collection costs that exceed the usual

expenses incurred in the collection of NFLP loan funds.

C. Cash Management

ED provides funds to an institution under the advance, reimbursement, or cash

monitoring payment methods.

The advance payment method is the most widely used payment method. It permits, but

does not require, institutions to draw down Title IV funds prior to disbursing funds to

eligible students and parents. The institution’s request must not exceed the amount

immediately needed to disburse funds to students or parents. A disbursement of funds

occurs on the date an institution credits a student’s account or pays a student or parent

directly with either SFA funds or institutional funds. The institution must make the

disbursements as soon as administratively feasible, but no later than 3 business days

following the receipt of funds. Any amounts not disbursed by the end of the third

business day are considered to be excess cash and generally are required to be promptly

returned to ED (34 CFR section 668.166(a)(1)). Excess cash includes any funds received

from ED that are deposited or transferred to the institution’s Federal account as a result of

an award adjustment, cancellation, or recovery. However, an excess cash balance

tolerance is allowed if that balance (1) is less than one percent of its prior-year

drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections

668.166(a) and (b)). Except for FPL program earnings, aggregate interest earnings

greater than $500 must be remitted to the Department of Health and Human Services

(HHS). FPL earnings are reinvested in the FPL fund (34 CFR sections 674.8(a)(6) and

668.163(c)).

Under the reimbursement payment method, the institution must disburse funds to the

students before requesting funds from ED. Under the cash monitoring payment method,

the institution must disburse funds to students before requesting funds from ED under

either the advance payment method (limited to the actual disbursement amount, known as

“Heightened Cash Monitoring 1”) or a process similar to the reimbursement method

(known as “Heightened Cash Monitoring 2”). (See Chapter 1, “Requesting & Managing



FSA Funds” in Volume 4, of the FSA Handbook, for guidance on the funding methods.

The handbook may be accessed from links at:

https://ifap.ed.gov/ifap/byAwardYear.jsp?type=fsahandbook).

Institutions request funds from ED by (1) creating a payment request using the G5

System through the Internet; or (2) if the grantee is placed on the reimbursement or cash

monitoring 2 payment method, submitting a Form 270, Request for Title IV

Reimbursement or Heightened Cash Monitoring 2 (HCM2) (OMB No. 1845-0089) to an

ED program or regional office. When creating a payment request in G5, the grantee

enters the drawdown amounts, by award, directly into G5. Direct Loan schools and

grantees can redistribute drawn amounts between grant awards by making adjustments in

G5 to reflect actual disbursements for each award as long as the net amount of the

adjustments is zero. When requesting funds using the other two methods, institutions

provide drawdown information to the hotline operator or on the Form 270, as applicable.

To assist institutions in reconciling their internal accounting records with the G5 System,

using their DUNS (Data Universal Numbering System) number, institutions can obtain a

G5 External Award Activity Report (https://www.g5.gov/; under the “Payment” tab)

showing cumulative and detail information for each award. The External Award Activity

Report can be created with date parameters (Start and End Dates) and viewed on-line. To

view each draw per award, the G5 user may click on the award number to view a display

of individual draws for that award.

For the HHS programs, requests for new FCC must only be made when needed. Any

monies associated with the fund must be deposited in an income-producing account and

all excess cash, including interest earned in excess of $500 in the aggregate, must be

returned to HHS.

For HPSL/PCL/LDS, and NSL, the school must maintain all monies relating to each

individual fund in interest bearing accounts. If the school integrates the funds with other

school resources for investment purpose, the school must maintain separate

accountability and reimburse the funds for any losses that occur (HPSL/PCL/LDS 42

CFR sections 57.203 and 57.205; NSL, 42 CFR sections 57.303 and 57.305).

For NFLP (CFDA 93.294), the school must maintain all monies relating to each

individual fund in interest-bearing accounts. Any monies associated with the fund must

be deposited in an income-producing account and all excess cash, including any interest

earned in excess of $500 in the aggregate, must be returned to HHS. Unused loan funds

should be retained in the loan fund for making additional loans. However, unused NFLP

funds must be used within 18 calendar months from the end of the NFLP designated

budget period. The unused accumulation (cash balance) in the NFLP fund must be

reported annually. The NFLP loan fund may be voluntarily or involuntarily terminated if

the unused accumulation is deemed excessive. If a school is determined to have an

excessive unused accumulation, future awards may be affected (Program Guidance,

Overview of Institutional Management of NFLP Funds).

https://www.g5.gov/



E. Eligibility

1. Eligibility for Individuals

Most of the requirements for student eligibility are contained in Appendix A

(located after Section IV, “Other Information,” of this Part 5).

In the process of a student applying for ED Federal financial aid, an Institutional

Student Information Record (ISIR) normally is sent electronically to the

institution and a Student Aid Report (SAR) may be sent to the student. The

original ISIR or SAR for an award year may contain codes that relate to student

eligibility requirements numbers 2, 4, 5, 9, 10, and 12 in Appendix A. If the

original ISIR or SAR does not contain codes relating to those eligibility

requirements, and the institution has no information indicating otherwise, the

student can be considered to have met them. The ISIR Guide contains all the ISIR

and SAR codes and is available at

http://www.ifap.ed.gov/ifap/byAwardYear.jsp?type=isirguide. The ISIR Guide

changes annually and should be obtained and reviewed for the period under audit.

Calculation of Benefits

In addition to the requirements and limits described below, awards must be

coordinated among the various programs and with other Federal and non-Federal

aid (need and non-need based aid) to ensure that total aid is not awarded in excess

of the student’s financial need (34 CFR section 668.42, FPL, FWS, and FSEOG,

34 CFR sections 673.5 and 673.6; Direct Loan, 34 CFR section 685.301; HPSL,

PCL, and LDS, 42 CFR section 57.206; NSL, 42 CFR section 57.306(b)); NFLP,

Affordable Care Act, Section 5311 and Program Guidance). The TEACH Grant

is a non-need based grant and may replace a student’s EFC, but the amount of the

grant that exceeds the student’s EFC is considered estimated financial assistance

(34 CFR section 686.21(d)). An IASG-eligible student who has an EFC that does

not meet the needs-based criteria for a Pell grant can receive a non-needs based

IASG and the maximum amount of a Pell award available, but the (1) award may

not exceed the student’s cost of attendance (COA) and (2) IASG is not considered

estimated financial assistance (20 USC 1070h).

The determination of SFA award amounts is based on financial need. Financial

need is generally defined as the student’s COA minus financial resources

reasonably available. In determining the financial resources available for the

HHS programs, the school must use one of the need analysis systems or any other

procedures approved by the Secretary of Education. The school must also take

into account other information that it has regarding the student’s financial status.

For Title IV programs, the financial resources available is generally the Expected

Family Contribution (EFC) that is computed by the central processor and included

on the student’s SAR and the ISIR provided to the institution.

http://www.ifap.ed.gov/ifap/byAwardYear.jsp?type=isirguide



An institution may (1) exclude, from both estimated financial assistance and the

COA, financial assistance provided by a State if that assistance is designated by

the State to offset a specific component of the COA; (2) include the one-time cost

of a student obtaining his or her first professional license or certificate; and

(3) include room and board in a student’s COA for students who are less than

half-time students (Sections 480(j)(3), 472(13), and 472(4)(C) of HEA; (20 USC

1087vv(j)(3), 20 USC 1087ll(13) and (4)(C))).

For Title IV programs, the COA is generally the sum of the following: tuition and

fees; an allowance for books, supplies, transportation and miscellaneous personal

expenses; an allowance for room and board; where applicable, allowances for

costs for dependent care; costs associated with study abroad and cooperative

education; costs related to disabilities; and fees charged for student loans. There

are exceptions for students attending less than half-time, correspondence students,

and incarcerated students. The financial aid administrator also has authority to

use professional judgment to adjust the COA or alter the data elements used to

calculate the EFC on a case-by-case basis to allow for special circumstances.

For the HHS programs, the costs reasonably necessary for the student’s

attendance include any special needs and obligations which directly affect the

student’s ability to attend the school. The school must document the criteria used

for determining these costs.

(20 USC 1087ll-1087mm; FPL, 34 CFR section 674.9; FWS, 34 CFR section

675.9; FSEOG, 34 CFR section 676.9; Direct Loan, 34 CFR sections 685.200 and

301; Pell, 34 CFR section 690.75; HPSL/PCL/LDS, 42 USC 293a(d)(2); 42 CFR

section 57.206(b); NSL, 42 USC 297n-1(c)(2); 42 CFR section 57.306(b)); NFLP,

Affordable Care Act, Section 5311 and Program Guidance)

Health Professions Student Loans/Primary Care Loans)/Loans for Disadvantaged

Students (CFDA 93.342), Nursing Student Loans (CFDA 93.364)

For periods prior to November 13, 1998, the total amount of HPSL/PCL/LDS

loans made to a student for a school year may not exceed $2,500 plus the cost of

tuition (42 CFR section 57.207). For students who are applying for a

HPSL/PCL/LDS loan, the school must make its selection based on the order of

greatest financial need, taking into consideration the other resources available to

the student. The resources may include summer earnings, educational loans,

veteran (G.I.) Benefits, and earnings during the school year (HPSL/PCL/LDS,

42 CFR section 57.206(c)). For periods after November 13, 1998, the total

amounts of HPSL/PCL/LDS loans to a student for a school year may not exceed

the cost of attendance (including tuition, other reasonable educational expenses,

and reasonable living expenses). The amount of the loan may, in the case of the

third or fourth year of a student at a school of medicine or osteopathic medicine,

be increased to pay balances of loans that were made to the individual for

attendance at the school (42 USC 722(a)(1) (section 722(a)(1) of PHS Act);

Pub. L. No. 105-392, sections 134 (1) and (2)). The total amount of NSL loans



made to a student for an academic year may not exceed $3,300 except that for

each of the final 2 academic years of the program the total must not exceed

$5,200. The total of all NSL loans may not exceed $17,000 (Section 5202 (a) of

the Affordable Care Act).


The total amount of NFLP loans made to a student for a school year may not

exceed $35,500 for a maximum of 5 years to support the cost of tuition, fees,

books, laboratory expenses and other reasonable education expenses. NFLP loans

do not include stipend support (i.e., living expenses, student transportation cost,

room/board, personal expenses). For students who are applying for a NFLP loan,

the student must be enrolled full-time or part-time in an eligible graduate

(master’s and doctoral) nursing education program at the school. The school must

make its selection of NFLP student applicants to receive loan funds by taking into

consideration the other resources available to the student. Section 847(f) added a

funding priority for Sections 847 and 846A of the PHS Act. This funding priority

is awarded to school of nursing student loan funds that support doctoral nursing

students. Schools that receive the doctoral funding priority should fund new

doctoral student applicants ahead of new master’s student applicants (Title VIII,

Section 846A, PHS Act, as amended by the Patient Protection and Affordable

Care Act of 2010, Pub. L. No.111-148, Section 5311).

Scholarships for Disadvantaged Students (CFDA 93.925)

Individual student awards must be at least 50 percent of the student’s annual

tuition costs. The maximum amount of $30,000 must be awarded for students

whose tuition is more than $60,000; however, no student can be awarded SDS

funds greater than $30,000 in a given year. Scholarships will be awarded by

schools to any full-time student who is from a disadvantaged background; has a

financial need for a scholarship; and is enrolled (or accepted for enrollment) in a

program leading to a degree in a health profession or nursing. Such scholarships

may be expended only for tuition expenses, other reasonable educational

expenses, and reasonable living expenses incurred in the attendance of such

school (42 USC 293a; Section 737, PHS Act).

Federal Pell Grant (CFDA 84.063)

Each year, based on the maximum Pell grant established by Congress, ED

provides to institutions Payment and Disbursement Schedules for determining

Pell awards (https://ifap.ed.gov/dpcletters/GEN1619.html). The Payment or

Disbursement Schedule provides the maximum annual amount a student would

receive for a full academic year for a given enrollment status, EFC and COA.

The Payment Schedule is used to determine the annual award for a full-time

student. There are separate Disbursement Schedules for three-quarter time, half-

time, and less-than-half-time students. All of the Schedules, however, are based

on the COA of a full-time student for a full academic year (see Chapter 3 in



Volume 3, Calculating Pell and Iraq & Afghanistan Service Grant Awards, of the

FSA Handbook for the year(s) being audited for guidance on selecting formulas

for calculating cost of attendance, prorating costs for programs less or greater than

an academic year, and determining payment periods).

Students that receive Pell or IASG may not receive more than six Scheduled

Awards (12 semesters, or the equivalent) as measured by the percentage of

“lifetime eligibility used” (LEU) field in COD (tracked by ED) (20 USC

1070a(c)(5)).

The steps to determine Pell awards are as follows:

(1) Determine the student’s enrollment status (full-time, three-quarter time,

half-time, or less than-half-time).

(2) Calculate the cost of attendance. This is always based on the cost for a

full-time enrollment status for a full academic year. If the student is

enrolled in a program or enrollment period that is longer or shorter than an

academic year, the costs must be prorated so that they apply to one full

academic year. There are two allowable proration methods. Costs can be

on an actual cost-per-student basis or an average cost for groups of similar

students. If the student is enrolled less than half-time, the only allowable

cost components are tuition and fees, allowance for books and supplies,

transportation allowance, allowance for dependent care, and room and

board.

(3) Determine the annual award, based on the cost of attendance calculated

above and the EFC, from the Payment or Disbursement Schedule for the

student’s enrollment status (i.e., full-time, three quarter-time, half-time, or

less than half-time).

(4) Determine the payment period. For term programs (semester, trimester,

quarter), the payment period is the term.

(5) Calculate the payment for the payment periods. The calculation of the

payment for the payment period may vary depending on the formula used,

the length of the program compared to the academic year, and whether the

institution uses an alternative calculation for students who attend summer

terms (34 CFR sections 690.61 through 690.67. Also see Chapter 3 in

Volume 3, Calculating Pell and Iraq & Afghanistan Service Grant Awards,

of the FSA Handbook.

(6) Disburse funds at prescribed times (This is tested under III.N.3, “Special

Tests and Provisions ˗ Disbursements To or On Behalf of Students”) (34

CFR sections 690.61 through 690.67, and 690.75 through 690.76; Pell

Grant Payment Schedules; General Provisions regulations, part 668,

subpart K, and FSA Handbook).



Postsecondary Education Scholarships for Veteran’s Dependents (Iraq and

Afghanistan Service Grant) (CFDA 84.408)

A non-Pell eligible student whose parent or guardian died as a result of U.S.

military service in Iraq or Afghanistan after September 11, 2001, can receive an

IASG grant. The student must have been less than 24 years old or, if 24 years old

or older, enrolled in at an institution of higher education when the parent or

guardian died. The amount of the grant is the same as the Pell Grant the student

would be eligible for if they had a zero EFC. All other Pell requirements apply

but, unlike Pell Grants, these non-need-based grants do not count as estimated

financial assistance (20 USC 1070h; FSA Handbook, Volume 1, Chapter 6; and

electronic announcement dated November 6, 2009

(http://ifap.ed.gov/eannouncements/110609DODMatch.html)).

Campus-Based Programs (FPL, FWS, FSEOG) (CFDA 84.038, CFDA 84.033,

CFDA 84.007)

The maximum amount that can be awarded under the campus-based programs is

equal to the student’s financial need (COA minus EFC) minus aid from other SFA

programs and other resources. For programs of study or enrollment periods less

than or greater than an academic year, the COA for loans and campus-based aid is

based on the student’s actual costs for the period for which need is being

analyzed, rather than being prorated to the costs for a full-time student for a full

academic year. The financial aid administrator has discretion in awarding

amounts from each program, subject to certain limitations.

Federal Supplemental Educational Opportunity Grants (CFDA 84.007)

The FSEOG program provides grants to eligible undergraduate students. Priority

is given to Federal Pell recipients who have the lowest expected family

contributions. The institution decides the amount of the grant, which can be up to

$4,000 but not less than $100, for an academic year. The maximum amount may

be increased to $4,400 for a student participating in a study abroad program that is

approved for credit by the student’s home institution (34 CFR sections 676.10 and

676.20).

TEACH Grants (CFDA 84.379)

The TEACH Grant is a non-need-based grant that provides annual grants of up to

$4,000 to eligible undergraduate and graduate students who agree to teach

specified high-need subjects at schools serving primarily disadvantaged

populations for 4 years within 8 years of graduation. The aggregate amount of

TEACH Grants that a candidate may receive for undergraduate or post-

baccalaureate study may not exceed $16,000. The aggregate amount that a

graduate student may receive may not exceed $8,000. If the student is enrolled

less than full-time, including less than half-time, the amount of the annual

TEACH Grant that he or she may receive must be reduced in accordance with

http://ifap.ed.gov/eannouncements/110609DODMatch.html



34 CFR section 686.21. The amount of the TEACH Grant, in combination with

other assistance the student may receive, may not exceed the cost of attendance.

If the TEACH Grant and other aid exceeds the cost of attendance for an academic

year, the student’s aid package must be reduced. The TEACH Grant may replace

a student’s EFC, but the amount of the grant that exceeds the student’s EFC is

considered estimated financial assistance. (34 CFR section 686.21)


Annual loan maximums for the FPL program are $5,500 for a student who has not

successfully completed a program of undergraduate education; and $8,000 for a

graduate or professional student. The aggregate loan maximums for the FPL

program are $11,000 cumulative for a student who has not successfully completed

2 years of a program leading to a bachelor’s degree; $27,500 cumulative for a

student who has successfully completed 2 years of a program leading to a

bachelor’s degree, but who has not completed the work necessary for the degree;

and $60,000 cumulative for a graduate or professional student, including loans

borrowed as an undergraduate student (34 CFR section 674.12 and the FSA

Handbook and Pub. L. No. 110-315, Section 464(a) (20 USC 1087dd(a))).

The Perkins Loan Extension Act of 2015 (Extension Act) (Pub. L. No. 114-105)

extended the FPL program through September 30, 2017. Under the Extension

Act, schools may not award Perkins Loans to graduate students after September

30, 2016. Schools may not make subsequent disbursements of Perkins Loans to

graduate students after June 30, 2017. Schools may not award Perkins Loans to

undergraduate students after Sept. 30, 2017. Schools may not make subsequent

disbursements to undergraduate students after June 30, 2018. The Extension Act

also established additional requirements for the awarding of Perkins Loans. ED

issued a Dear Colleague Letter, dated February 17, 2016 (GEN-16-05), explaining

these additional requirements. GEN-16-05 is available

at http://ifap.ed.gov/dpcletters/GEN1605.html.

Federal Direct Student Loans (CFDA 84.268)

In determining loan amounts for subsidized Stafford loans, the financial aid

administrator subtracts from the COA, the EFC and the estimated financial

assistance for the period of enrollment that the student (or parent on behalf of the

student) will receive from Federal, State, institutional or other sources.

Unsubsidized Stafford loans, PLUS loans, loans made by a school to assist the

student, and State-sponsored loans may be used to substitute for EFC

(34 CFR sections 685.102 and 685.200(d)). A financial aid administrator may use

discretion to offer an unsubsidized Stafford loan to a dependent student whose

parents do not support the student and who refuse to complete a FAFSA (20 USC

1087tt(a)).

http://ifap.ed.gov/dpcletters/GEN1605.html



The annual loan limits apply to the length of the school’s academic year. Except

for PLUS loans and for graduate or professional students, proration of a loan is

required when a program is less than an academic year as measured in either

clock hours or credit hours or number of weeks; or when a program exceeds an

academic year but the remaining portion of the program is less than an academic

year in length. Effective May 16, 2013, there is a limit on Direct Subsidized Loan

eligibility for new borrowers on or after July 1, 2013. Specifically, a new

borrower on or after July 1, 2013 becomes ineligible to receive additional Direct

Subsidized Loans if the period during which the borrower has received such loans

exceeds 150 percent of the published length of the borrower’s educational

program. The borrower also becomes responsible for accruing interest during all

periods as of the date the borrower exceeds the 150 percent limit (34 CFR section

685.200(f)). For the purpose of determining loan limits for a borrower who

received an Associate or Bachelor degree and has re-enrolled in another eligible

program for which the prior degree is a prerequisite, the number of years that a

student has completed in a program of undergraduate study includes any prior

enrollment.

Annual Limits for Subsidized Loans

For an undergraduate student who has not yet successfully completed the first

year of study, the annual loan limit is $3,500 for a program of study at least an

academic year in length. For a program of less than an academic year, the loan

must be prorated. Programs less than one-third of an academic year are not

eligible for these loans.

For an undergraduate student who has successfully completed the first year but

has not successfully completed the second year of an undergraduate program:

(1) up to $4,500 for a program of study at least an academic year in length, and

(2) for programs with less than an academic year remaining, the loan must be

prorated. Programs less than one-third of an academic year are not eligible for

these loans.

For an undergraduate student who has successfully completed the first and second

year of study but has not successfully completed the remainder of the program or

for a student in a program who has an associate or baccalaureate degree which is

required for admission into the program: (1) up to $5,500 for a program of study

at least an academic year in length, and (2) for programs with less than an

academic year remaining, the loan must be prorated.

Annual Limits for Unsubsidized Loans

A student may receive an unsubsidized loan for the amount that is the difference

between the subsidized amount for which he or she was eligible and the

subsidized amount that he or she received. For dependent undergraduate students,

the unsubsidized loan is the difference between the student’s cost of attendance



and the student’s estimated financial assistance (including a subsidized loan if the

student qualifies for one).

Additional eligibility for unsubsidized loans, beyond the base

subsidized/unsubsidized amount, is available to all independent students and to

dependent students if the financial aid administrator determines that the dependent

students’ parents are likely to be precluded by exceptional circumstances from

receiving a PLUS loan.

An undergraduate dependent student, in any year of study, may receive an

additional $2,000 in unsubsidized loans for each year of study (except for

dependent students whose parents are unable to obtain a PLUS loan, which should

be noted in the student file). (Dear Colleague Letter GEN-08-08 which is located

at http://ifap.ed.gov/dpcletters/061908GEN0808.html and Dear Colleague Letter

GEN-11-07 which is located at http://www.ifap.ed.gov/dpcletters/GEN1107.html

(Section 2 of Pub. L. No. 110-227, which amended Section 428H(d) of HEA (20

USC 1078-8(d))).

For an independent student (and dependent students whose parents cannot borrow

a PLUS loan) who has not successfully completed the first 2 years of

undergraduate study: (1) up to an additional $6,000 for a program of study at

least an academic year in length, and (2) for programs with less than a full

academic year remaining, the loan must be prorated.

For a student who has successfully completed the first and second years of an

undergraduate program but who has not successfully completed the remainder of

the program: (1) up to an additional $7,000 for a program of study at least an

academic year in length, and (2) for programs with less than a full academic year

remaining, the loan must be prorated.

Graduate or professional students may borrow up to $20,500 per academic year in

unsubsidized loans.

Exceptions: Annual increased unsubsidized loan limits for certain health

professions students who previously borrowed under the HEAL program are

authorized. (See Volume 3, Chapter 5, of the FSA Handbook. The FSA

Handbook is available at http://ifap.ed.gov.)

Aggregate Loan Limits for Subsidized and Unsubsidized Loans

Aggregate loan limits for subsidized and unsubsidized loans are: $31,000 for a

dependent undergraduate student (except for dependent students whose parents

cannot borrow a PLUS loan) (subsidized loan portion may not exceed $23,000 of

the aggregate limit amount); $57,500 for an independent student and for a

dependent student whose parents cannot borrow a PLUS loan (subsidized loan

portion may not exceed $23,000 of the aggregate limit amount); and $138,500 for

a graduate or professional student (subsidized portion limited to $65,500). This

$138,500 limit includes loans for undergraduate study.

http://ifap.ed.gov/dpcletters/061908GEN0808.html

http://www.ifap.ed.gov/dpcletters/GEN1107.html

http://ifap.ed.gov/



Direct PLUS (PLUS)

PLUS loans are limited to parent borrowers of dependent undergraduate students

and graduate and professional students. A parent must meet the same citizenship

and residency requirements as a student. Similarly, a parent who owes a refund

on an SFA grant or is in default on an SFA loan is ineligible for a PLUS loan

unless satisfactory arrangements have been made to repay the grant or loan. A

PLUS loan may not exceed the student’s estimated cost of attendance minus other

financial aid awarded during the period of enrollment for that student (34 CFR

sections 685.101(b), 685.200, and 685.203).

2. Eligibility for Group of Individuals or Area of Service Delivery – Not

Applicable

3. Eligibility for Subrecipients – Not Applicable

G. Matching, Level of Effort, Earmarking

1. Matching


The institution’s matching share (ICC) is one third of the FCC (34 CFR section

674.8). Beginning with award year 2005-06, Congress has not appropriated FCC

for the FPL program. In years when no FCC is appropriated, schools are not

required to provide ICC.

Federal Supplemental Educational Opportunity Grants (CFDA 84.007)

The Federal share of awards may not exceed 75 percent of the total FSEOG

awards made by the school, unless a higher amount (up to 100 percent) has been

authorized by ED (34 CFR section 676.21).


Generally, the Federal share of FWS compensation paid a student employed other

than by a private for-profit organization may not exceed 75 percent of the total

FWS awards made by the school. However, the Federal share may exceed 75

percent, but not exceed 90 percent, for up to 10 percent of the students

compensated by FWS during the academic year, if, consistent with regulations of

the Secretary, the student is employed at a non-profit private organization or a

government agency that (1) is not a part of, and is not owned, operated, or

controlled by, or under common ownership, operation, or control with, the

institution; (2) is selected by the institution on an individual case-by-case basis for

such student; and (3) would otherwise be unable to afford the costs of such

employment (42 USC 2753(b)(5); 34 CFR section 675.26(a)).



The Federal share of FWS for work at private-for-profit organizations is limited to

50 percent (34 CFR section 675.26(a)(3)).

However, a Federal share of 100 percent is allowable when the work is performed

by the student for the institution, a public agency, or a private non-profit

organization and:

a. The institution is under the Tribally Controlled Colleges and Universities

Program or the Historically Black Colleges and Universities Program;

b. The institution received a waiver of the matching requirement from ED

(see http://www2.ed.gov/about/offices/list/ope/idues/eligibility.html)

under one of the following eligible programs:

(1) Developing Hispanic-Serving Institution Program,

(2) Strengthening Institutions Program,

(3) Alaskan Native and Native Hawaiian-Serving Institutions

Program,

(4) Asian American and Native American Pacific Islander-Serving

Institutions Program,

(5) Native American-Serving Nontribal Institutions Program,

(6) Hispanic-Serving Institutions and Articulation Program,

(7) Promoting Postbaccalaureate Opportunities for Hispanic

Americans Program, or

(8) Predominantly Black Institutions Program; or

c. The student is (1) employed as a reading tutor for preschool-age children

or elementary school children, (2) employed as a mathematics tutor for

children in elementary school through ninth grade, (3) employed in a

community service activity and performing civic education and

participation activities in a project, or (4) performing family literacy

activities in a family literacy project that provides services to families with

preschool-age children or elementary school children (34 CFR section

675.26(d); ED Notice, November 3, 2014, Federal Register (79 FR

65197); FSA Handbook, Volume 6, Chapter 1

http://www2.ed.gov/about/offices/list/ope/idues/eligibility.html



Health Professions Student Loan/Primary Care Loans/Loans for Disadvantaged

Students (CFDA 93.342), Nursing Student Loan (CFDA 93.364)

The institution’s ICC is one-ninth of the FCC and must be deposited in a health

professions student loan fund (42 CFR sections 57.202 and 57.302).


Schools that receive a FCC grant award must contribute an ICC amount equal to

not less than one-ninth of the total FCC grant award. The institution’s ICC must

be deposited in a NFLP loan fund at the school (Section 5311 of the Affordable

Care Act and Program Guidance, Section III.2).

2. Level of Effort - Not Applicable

3. Earmarking


An institution must use at least seven percent of the sum of its initial and

supplemental FWS allocations for an award year to compensate students

employed in community service activities unless waived by the Secretary of

Education. The institution can only use up to 10 percent of its FWS or $75,000,

whichever is less, for a JLD program (Section 446(a)(1) of the HEA (42 USC

2756); 34 CFR section 675.18).

J. Program Income


Principal and interest repayments made by students and reimbursements received for

canceled loans are reinvested in the FPL revolving fund (34 CFR section 674.8).

Note: Many institutions engage third-party servicers for billing and collection of

principal and interest repayments and reimbursements for canceled loans. Although these

institutions remain responsible for compliance, auditors of these institutions may exclude

testing of the portion of the program income compliance requirement performed by third-

party servicers.

L. Reporting

1. Financial Reporting

a. SF-270, Request for Advance or Reimbursement – Applicable to ED

programs (using the G5 System)

b. SF-271, Outlay Report and Request for Reimbursement for Construction

Programs – Not Applicable



c. SF-425, Federal Financial Report – Not Applicable for ED programs;

Applicable for HHS programs

d. Form 270, Request for Title IV Reimbursement or Heightened Cash

Monitoring 2 (HCM2) (OMB No. 1845-0089) – Applicable only to

institutions placed on reimbursement payment method or Heightened Cash

Monitoring 2 by ED.

e. Common Origination and Disbursement (COD) System (OMB No. 1845-

0039) –All schools receiving Pell grants submit Pell payment data to the

Department of Education through the COD System.

Schools submit Pell origination records and disbursement records to the

COD. Origination records can be sent well in advance of any

disbursements, as early as the school chooses to submit them for any

student the school reasonably believes will be eligible for a payment. A

school follows up with a disbursement record for that student no earlier

than (1) 7 calendar days prior to the disbursement date under the Advance

or Heightened Cash Monitoring 1 payment methods, or (2) the date of the

disbursement under the Reimbursement or Heightened Cash Monitoring

2 payment methods (see ED Notice, June 27, 2017, Federal Register (82

FR 29061). The disbursement record reports the actual disbursement date

and the amount of the disbursement. ED processes origination and/or

disbursement records and returns acknowledgments to the school. The

acknowledgments identify the processing status of each record: Rejected,

Accepted with Corrections, or Accepted. In testing the Pell Payment

origination and disbursement data, the auditor should be most concerned

with the data ED has categorized as accepted or accepted with corrections.

Institutions must report student payment data within 15 calendar days after

the school makes a payment, or becomes aware of the need to make an

adjustment to previously reported student payment data or expected

student payment data. Schools may do this by reporting once every 15

calendar days, bi-weekly or weekly, or may set up their own system to

ensure that changes are reported in a timely manner.

Key items to test on origination records are: Social Security Number,

award amount, enrollment date, verification status code, transaction

number, cost of attendance, and academic calendar. Key items to test on

disbursement records are disbursement date and amount. The information

may be accessed by the institution for the auditor (34 CFR section 690.83;

FSA Handbook, technical references on obtaining reports for each award

year are located at

https://ifap.ed.gov/ifap/byAwardYear.jsp?type=codtechref&display=singl

e, COD Technical Reference, choose the award year, Volume VI,

Appendices, Section 8).

2. Performance Reporting – Not Applicable



3. Special Reporting

ED Form 646-1, Fiscal Operations Report and Application to Participate

(FISAP) (OMB No. 1845-0030) - This electronic report is submitted annually to

receive funds for the campus-based programs. The school uses the Fiscal

Operations Report portion to report its expenditures in the previous award year

and the Application to Participate portion to apply for the following year. By

September 29, 2017, the institution should submit its FISAP that includes the

Fiscal Operations Report for the award year 2016-2017 and the Application to

Participate for the 2018-2019 award year (FPL, FWS, FSEOG 34 CFR section

673.3; Instruction Booklet for Fiscal Operations Report and Application to

Participate).

Key Line Items – The following line items contain critical information:

Part I, Identifying Information

Part II, Application

- Information on enrollment

- Assessments and expenditures

- Information on eligible aid applicants

Part III, Federal Perkins Loan Program

- Fiscal Report (Trace material line items)

- Fund Activity (Annual) During the XXXX-XX Award Year

- Cumulative Repayment Information

- Cohort Default Rate

Part IV, Federal Supplemental Educational Opportunity Grant Program

- All sections

Part V, Federal Work-Study (FWS) Program

- All sections

Part VI, Program Summary for Award Year

- Distribution of Program Recipients and Expenditures by Type of Student

(Trace a sample of line items)

N. Special Tests and Provisions



1. Separate Funds (HPSL/PCL/LDS, NSL, FPL)

Compliance Requirement – The institution must maintain a separate fund account for

each program (HPSL/PCL/LDS, 42 CFR section 57.205; NSL, 42 CFR section 57.305;

and FPL, 34 CFR sections 674.8 and 674.19).

Audit Objective – Determine whether separate fund account(s) were established.

Suggested Audit Procedures

Review accounting records to verify that a separate fund was established for each

program.

2. Verification

Compliance Requirements – An institution may participate under an ED-approved

Quality Assurance Program (QAP) that exempts it from verifying those applicants

selected by the central processor, provided that the applicants do not meet the

institution’s own verification selection criteria (20 USC 1094a; HEA Section 487A)

(FSA Handbook, Application and Verification Guide, Chapter 4). An institution not

participating under an ED-approved QAP is required to establish written policies and

procedures that incorporate the provisions of 34 CFR sections 668.51 through 668.61 for

verifying applicant information. Such an institution shall require each applicant whose

application is selected by ED to verify the information required for the Verification

Tracking Group to which the applicant is assigned. Dear Colleague Letter GEN-16-07

explains the 2017-2018 Verification Tracking Groups and the information required to be

verified for each group. GEN-16-07 is available at

https://ifap.ed.gov/dcpletters/GEN1607.html. However, certain applicants are excluded

from the verification process as listed in 34 CFR section 668.54(b). Specified

verification items and acceptable documentation will be listed in the Federal Register.

For award year 2017-2018, the Federal Register notice was published April 1, 2016

(https://ifap.ed.gov/fregisters/attachments/FR040116FAFSA20172018BeVerified ) (also

see Appendix B to this Part 5).

The institution shall also require applicants to verify any information used to calculate an

applicant’s EFC that the institution has reason to believe is inaccurate (34 CFR section

668.54(a); FSA Handbook Application and Verification Guide, Chapter 4).

Acceptable documentation for the verification is listed in 34 CFR section 668.57 and in

the annual Federal Register update and in Appendix B located after Section IV, “Other

Information,” of this Part 5.

Audit Objectives – Determine whether the institution established policies and

procedures to verify information in student aid applications, and verified all required

information of selected applications in accordance with the requirements.




a. Review the institution’s policies and procedures for verifying student applications

and verify that they meet the requirements either of 34 CFR section 668.53 or, if

applicable, the institution’s QAP.

b. If the institution has a QAP, select a sample of applications and review records to

ensure that the processes required under the approved QAP were applied.

c. If the institution does not have a QAP, select a sample of applications that were

selected by ED for verification and review the student aid files for those

applications to ascertain that the institution (1) obtained acceptable documentation

to verify the information required for the Verification Tracking Group to which

the applicant is assigned; (2) matched information on the documentation to the

student aid application; and, (3) if necessary, submitted data corrections to the

central processor and recalculated awards.

3. Disbursements to or on Behalf of Students


Title IV Programs - General

a. The payment period for a student enrolled in an eligible program that measures

progress in credit hours and has standard academic terms (semesters, trimesters,

or quarters), or has non-standard terms that are substantially equal in length, is the

academic term (34 CFR section 668.4(a)). (Non-standard terms are substantially

equal in length if no term is more than 2 weeks of instructional time longer than

any other term (34 CFR section 668.4(h)).

b. The payment period for a student enrolled in an eligible program that measures

progress in credit hours and uses non-standard terms that are not substantially

equal in length is as follows (34 CFR section 668.4(b)):

(1) For Pell Grant, IASG, FSEOG, Perkins, and TEACH Grants, the payment

period is the academic term.

(2) For Direct Loans,

(a) If the program is one academic year or less in length, (i) the first

payment period is the period of time in which the student

successfully completes half the number of credit hours in the

program and half the number of weeks of instructional time in the

program, and (ii) the second payment period is the period of time

in which the student completes the program.

(b) If the program is more than one academic year in length–



(i) For the first academic year and any subsequent full

academic year:

(A) The first payment period is the period of time in

which the student successfully completes half the

number of credit hours in the academic year and

half the number of weeks of instructional time in

the academic year; and

(B) The second payment period is the period of time in

which the student completes the academic year.

(ii) For any remaining portion of an eligible program that is

more than half, but less than a full, academic year in length:

(A) The first payment period is the period of time in

which the student successfully completes half the

number of credit hours in the remaining portion of

the program and half the number of weeks of

instructional time in the remaining portion of the

program; and

(B) The second payment period is the period of time in

which the student successfully completes the

remainder of the program.

(iii) For any remaining portion of an eligible program that is not

more than half an academic year, the payment period is the

remainder of the program.

c. The payment period for a student enrolled in an eligible program that measures

progress in credit hours and does not have academic terms or for a program that

measures progress in clock hours (34 CFR section 668.4(c)):

(1) If the program is one academic year or less in length, (a) the first payment

period is the period of time in which the student successfully completes

half the number of credit or clock hours in the program and half the

number of weeks instructional time in the program; and (b) the second

payment period is the period of time in which the student successfully

completes the program.

(2) If the program is more than one academic year in length–

(a) For the first academic year and any subsequent full academic year,

(i) the first payment period is the period of time in which the

student successfully completes half the number of credit or clock

hours in the academic year and half the number of weeks of

instructional time in the academic year, and (ii) the second




successfully completes the academic year.

(b) For any remaining portion of an eligible program that is more than

half but less than a full academic year in length, (i) the first


successfully completes half the number of credit or clock hours in

the remaining portion of the program and half the number of weeks

of instructional time in the remaining portion of the program, and

(ii) the second payment period is the period of time in which the

student successfully completes the remainder of the program.

(c) For any remaining portion of an eligible program that is not more

than half an academic year, the payment period is the remainder of

the program.

d. If an institution is unable to determine when a student has successfully completed

half of the credit hours in a program, academic year, or remainder of a program,

the student is considered to begin the second payment period of the program,

academic year, or remainder of a program at the later of (i) the date the institution

determines the student has completed half of the academic coursework in the

program, academic year, or remainder of the program; or (ii) half the number of

weeks of instructional time in the program, academic year, or remainder of the

program (34 CFR section 668.4(c)(3)).

If a student withdraws from a credit-hour program that does not have academic

terms or a clock-hour program during a payment period and reenters the same

program within 180 days, the student remains in that same payment period upon

reentry and is eligible to receive, subject to conditions established by ED, any

Title IV funds for which they were eligible prior to withdrawal, including funds

returned as a result of a return of funds calculation (34 CFR section 668.4(f)).

If a student withdraws from a credit-hour program that does not have academic

terms or a clock-hour program during a payment period and reenters the same

program after 180 days or transfers into another program (either at the same

institution or at a different institution) at any time, the student generally starts a

new payment period (34 CFR section 668.4(g)). (See exception to this general

rule in 34 CFR section 668.4(g)(3)).

e. The institution may not make a disbursement to a student for a payment period

until the student is enrolled in classes for that payment period, unless the student

is registered at least half-time (34 CFR section 668.32(a)(2)) and the loans are

disbursed by electronic funds transfer (EFT) to an account of the school or by

master check. In those situations, the school must obtain the student’s (or in the

case of parent a PLUS loan, the parent borrower’s) written authorization for the

release of the initial and any subsequent disbursement of each loan, unless

authorization was provided in the loan application or Master Promissory Note.



The institution must deliver the proceeds to the student or borrower or credit the

student’s account, notifying the student or parent borrower in writing (34 CFR

section 668.165). The earliest an institution may disburse SFA funds (other than

FWS) (either by paying the student directly or crediting the student’s account) is

10 days before the first day of classes of the payment period for which the

disbursement is intended (34 CFR section 668.164(i)). (If an institution uses its

own funds, i.e., funds not drawn down from ED, earlier than 10 days before the

first day of classes, ED considers that the institution made that disbursement on

the 10th

day before the first day of classes (34 CFR section 668.164(a)(2)). There

are two exceptions to this rule. First, institutions may not disburse or deliver the

first installment of Direct Loans to first-year undergraduates who are first time

borrowers until 30 days after the student’s first day of classes (34 CFR section

668.164(i)(2)), unless the institution has low default rates as discussed in the next

paragraph. The second exception applies to a student who is enrolled in a clock

hour educational program or a credit hour program that is not offered in standard

academic terms. The earliest the institution may disburse funds is the later of 10

days before the first day of classes for the payment period or, except for certain

circumstances under the Direct Loan program, the day the student completed the

previous payment period (34 CFR section 668.164(i)(1)). The excepted

circumstances for Direct Loan programs are described in 34 CFR sections

685.303(d)(3)(ii), (d)(5), and (d)(6) (34 CFR section 668.164(i)).

f. The exceptions for institutions to disburse loans for first-year undergraduates who

are first-time borrowers are (1) an institution with cohort default rates of less than

15 percent for each of the 3 most recent fiscal years for which data are available

does not have to wait the 30 days, and (2) an institution that is an eligible home

institution that certifies a loan to cover the student’s cost of attendance in a study-

abroad program and has a cohort default rate of less than 5 percent for the single

most recent fiscal year for which data are available does not have to wait the 30

days (34 CFR section 685.303(b)(5)).

g. The institution must notify the student, or parent, in writing of (1) the date and

amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all

or a portion of that loan or loan disbursement and have the loan proceeds returned

to the holder of that loan or the TEACH Grant payments returned to ED; and

(3) the procedure and time by which the student or parent must notify the

institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH

Grant disbursement. The notification requirement for loan funds applies only if

the funds are disbursed by EFT payment or master check (34 CFR section

668.165). Institutions that implement an affirmative confirmation process (as

described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the

student or parent no earlier than 30 days before, and no later than 30 days after,

crediting the student’s account at the institution with Direct Loan, FPL funds, or

TEACH Grants. Institutions that do not implement an affirmative confirmation

process must notify a student no earlier than 30 days before, but no later than 7

days after, crediting the student’s account and must give the student 30 days

(instead of 14) to cancel all or part of the loan.



h. An institution must return to ED (notwithstanding any State law, such as a law

that allows funds to escheat to the State) any Title IV funds, except FWS program

funds, that it attempts to disburse directly to a student or parent but they do not

receive or negotiate those funds. For FWS program funds, the institution is

required to return only the Federal portion of the payroll disbursements. If the

institution attempted to disburse the funds by check and the check is not cashed,

the funds must be returned no later than 240 days after the date it issued the

check. If a check is returned, or an EFT is rejected, the institution may make

additional attempts to disburse the funds, provided that the attempts are made no

later than 45 days after the funds were returned or rejected. If the institution does

not make an additional attempt to disburse the funds, the funds must be returned

before the end of the 45-day period and no later than 240 days from the date of

the initial attempt to disburse the funds (34 CFR section 668.164(l)).

i. If a student received financial aid while attending one or more other institutions,

schools are required to request financial aid history using the NSLDS Student

Transfer Monitoring Process. Under this process, a school informs NSLDS about

its transfer students. NSLDS will “monitor” those students on the school’s

“inform” list and alert the school of any relevant financial aid history changes. A

school must wait 7 days after it “informs” NSLDS about a transfer student before

disbursing Title IV aid to that student. However, a school does not have to wait if

it receives an alert from NSLDS during the 7-day period or if it obtains the

student’s financial aid history by accessing the NSLDS Financial Aid Professional

website. When a school receives an alert from NSLDS, before making a

disbursement of Title IV aid, it must determine if the change to the student’s

financial aid history affects the student’s eligibility (34 CFR section 668.19).

j. For students whose applications were selected for verification, if the institution

has reason to believe that information included in the application is inaccurate, the

institution may not (1) disburse any Pell or campus-based aid, (2) employ the

applicant in its FWS program, or (3) originate Direct Loans (or process proceeds

of previously originated loans) until the applicant verifies or corrects the

information. If the institution does not have any reason to believe that the

information is inaccurate, the institution may withhold payment of Pell or

Campus-based aid, or may make one interim disbursement of Pell or Campus-

based aid, employ or allow an employer to employ an eligible student under FWS

for the first 60 consecutive days after the student’s enrollment and may originate

the Direct Loan, but cannot process the proceeds. If the verification process is not

complete within the time period specified, the institution shall return loan

proceeds. In addition, the institution is liable for an interim disbursement if

verification shows that a student received an overpayment or if the student fails to

complete verification (34 CFR sections 668.58, 668.60(b)(3), and 668.61)).



Pell

To disburse Pell funds, the institution must have received a valid ISIR from the central

processor or a valid SAR from the student by the earlier of the student’s last date of

enrollment or the deadline date established by the Secretary in a notice published in the

Federal Register (the deadline date is normally in the month of September following the

end of the award year). Late disbursements of Pell for ineligible students are allowed if,

before the date the student became ineligible, an ISIR or SAR was processed that

contained an official expected family contribution. The institution has discretion in

disbursing funds within a payment period, but generally must disburse the full amount

before the end of the payment period.

The institution must review and document the student’s eligibility before it disburses

funds each payment period (34 CFR sections 690.61, 690.75, 690.76, and 668.164(b)(3)).

(Requirements for student eligibility are found in Appendix A.)

IASG

IASG disbursements follow Federal Pell grant regulations (20 USC 1070h).

(Requirements for student eligibility are found in Appendix A.)

TEACH Grant

To disburse TEACH Grant funds, the institution must ensure that the student (a) is

eligible (per 34 CFR section 686.11), (b) has completed the initial or subsequent

counseling (required by 34 CFR section 686.32), (c) has signed an agreement to serve

(required by 34 CFR section 686.12), (d) is enrolled in a TEACH grant-eligible program,

and (e) if enrolled in a credit-hour program without terms or a clock-hour program, has

completed the payment period, as defined in 34 CFR section 668.4, for which he or she

will be paid a grant (34 CFR section 686.31). (Requirements for student eligibility are

found in Appendix A.)

FPL

If the institution is making a loan for a full academic year and uses standard academic

terms, the institution must advance a portion of the loan during each payment period. If

standard academic terms are not used, it must advance funds at least twice during the

academic year - once at the beginning and once at the midpoint. Loan payments must be

supported by a signed promissory note (34 CFR section 674.16). (Requirements for

student eligibility are found in Appendix A.)

Direct Loan

Except in the case of an allowable late disbursement (34 CFR section 685.303(d)), before

disbursing the loan proceeds, the institution must determine that the student maintained

continuous eligibility from the beginning of the loan period. An institution under the

advance payment method may not disburse loan proceeds until they have obtained a

legally enforceable promissory note. An institution under reimbursement or cash



monitoring payment method must have obtained a legally enforceable promissory note

and may request funds only for those that they have already disbursed funds to students

(34 CFR sections 685.301 and 685.303). (See III.C, “Cash Management,” for discussion

of payment methods.) (Requirements for student eligibility are found in Appendix A.)

HPSL/PCL/LDS and NSL

Student loans may be paid to or on behalf of student borrowers in installments considered

appropriate by the school, except that a school may not pay to or on behalf of any

borrowers more than the school determines the student needs for any given installment

period (e.g., semester, term, or quarter). However, effective November 13, 1998, the

amount of the loan may be increased, in the case of the third or fourth year of a student at

a school of medicine or osteopathic medicine, to pay balances of loans that were made to

the individual for attendance at the school (42 USC 292r(a)(2); Section 722r(a)(2) of the

PHS Act; Pub. L. No. 105-392, Section 134(a)(2)). At the time of payment a

HPSL/PCL/LDS borrower must be a full-time student, a NSL borrower must be at least a

half-time student (HPSL/PCL/LDS, 42 CFR section 57.209; NSL, 42 CFR section

57.309). Each student loan must be evidenced by a properly executed promissory note

(HPSL/PCL/LDS, 42 CFR section 57.208; NSL, 42 CFR section 57.308).


NFLP loans may be paid to or on behalf of student borrowers in installments considered

appropriate by the school, except that a school may not pay to or on behalf of any

borrowers more than the school determines the student needs for any given installment

period (e.g., semester, term, or quarter). At the time of payment, a NFLP borrower must

be enrolled full-time or part-time. Each student loan must be evidenced by a properly

executed promissory note (Program Guidance, Repayment Provision).

FWS

The student’s wages are earned when the work is performed. The institution shall pay the

student at least once per month. The Federal share must be paid by check or similar

instrument the student can cash on his or her endorsement, or as authorized by the

student, by crediting FWS funds to a student’s account or by EFT to a bank account

designated by the student. The institution may only credit the account for tuition, fees,

institutional room and board, and other school-provided goods and services (34 CFR

section 675.16). (Requirements for student eligibility are found in Appendix A.)

Audit Objectives - Determine whether disbursements to students were made or returned

to the funds provider in accordance with required time frames; and whether required

reviews were made and required documents and approvals were obtained before

disbursing SFA funds.




a. Review a sample of disbursements to students and verify that they were made or

returned in accordance with required time frames, and for Direct Loan schools

that are on the reimbursement or cash monitoring payment method, that the

institution only requested funds from ED for students to whom the institution had

already disbursed funds.

b. Review loan or other files to verify that the institution performed required

procedures and obtained required documents prior to disbursing funds.

4. Return of Title IV Funds

Compliance Requirements - Applicable After a Student Begins Attendance

When a recipient of Title IV grant or loan assistance withdraws from an institution during

a payment period or period of enrollment in which the recipient began attendance, the

institution must determine the amount of Title IV aid earned by the student as of the

student’s withdrawal date. If the total amount of Title IV assistance earned by the student

is less than the amount that was disbursed to the student or on his or her behalf as of the

date of the institution’s determination that the student withdrew, the difference must be

returned to the Title IV programs as outlined in this section and no additional

disbursements may be made to the student for the payment period or period of

enrollment. If the amount the student earned is greater than the amount disbursed, the

difference between the amounts must be treated as a post-withdrawal disbursement

(34 CFR sections 668.22(a)(1) through (a)(5)).

Post-withdrawal Disbursements

Post-withdrawal disbursements must be made from available grant funds before available

loan funds (34 CFR section 668.22(a)(6)). Post-withdrawal disbursements of grant funds

may be credited to the student’s account, without the student’s authorization, for current-

year outstanding charges for tuition, fees, and room and board (if contracted with the

institution) on the student’s account, up to the amount of those outstanding charges. For

current-year outstanding charges other than tuition, fees, and room and board (if

contracted with the institution), the institution must have the student’s authorization to

credit the student’s account with grant funds. Any grant funds not disbursed to the

student’s account must be disbursed to the student no later than 45 days after the date of

the institution’s determination that the student withdrew (34 CFR section

668.22(a)(6)(ii)(B)(1)).

Post-withdrawal disbursements of loan funds may be credited to the student’s account if

current-year outstanding charges exist on the student’s account, up to the amount of the

current-year outstanding charges only after obtaining confirmation from the student, or

parent in the case of a parent PLUS loan, that he or she still wishes to have some or all of

the loan funds disbursed.



If the institution wishes to credit the student’s account with a post-withdrawal

disbursement of loan funds or wishes to pay a post-withdrawal disbursement of loan

funds directly to the student, or parent in the case of a parent PLUS loan, the institution

must, within 30 days of the date the institution determines that the student withdrew, send

a written notification to the student, or parent in the case of a parent PLUS loan, that

a. Asks the student or parent if he or she wants a post-withdrawal disbursement of

some or all of the loan funds credited to the student’s account, or a post-

withdrawal disbursement of some or all of the loan funds as a direct

disbursement;

b. Explains that, if the borrower does not want the loan funds credited to the

student’s account, it is up to the school to decide whether it will disburse the loan

funds as a direct disbursement to the borrower;

c. Explains the obligation of the borrower to repay any loan funds disbursed; and

d. Explains that no post-withdrawal disbursement will be made (other than a credit

of grant funds to the student’s account for tuition and fees and room and board, if

contracted for with the institution, or a credit of grant funds for other institutional

charges for which the institution has the student’s authorization or a direct

disbursement of grant funds) unless the student or parent responds within 14 days

of the date the institution sent the notification (or a later time frame set by the

institution), or the institution chooses to make a post-withdrawal disbursement

based on a late response (34 CFR sections 668.22(a)(6) and 668.164(c)).

If a student or parent accepts a post-withdrawal disbursement of loan funds, the

institution must make the disbursement within 180 days after the date of the institution’s

determination that the student withdrew and in accordance with the request of the

recipient (34 CFR sections 668.22(a)(6)(iii)(C) and 668.164(c)(1), (c)(2), (c)(3), and (j)).

Subject to the above, an institution may credit a student’s account for minor prior-award-

year charges, if not more than $200 (34 CFR section 668.164(c)(3)).

Withdrawal Date

If an institution is required to take attendance the withdrawal date is the last date of

academic attendance, as determined by the institution from its attendance records. An

institution is required to take attendance if:

a. The institution is required to take attendance for some or all of its students by an

entity outside of the institution (such as the institution’s accrediting agency or

State agency);

b. The institution itself has a requirement that its instructors take attendance; or



c. The institution or an outside entity has a requirement that can only be met by

taking attendance or a comparable process, including, but not limited to, requiring

that students in a program demonstrate attendance in the classes of that program

or a portion of that program (34 CFR section 668.22(b)(3)).

If an institution is not required to take attendance, the withdrawal date is (1) the date, as

determined by the institution, that the student began the withdrawal process prescribed by

the school; (2) the date, as determined by the institution, that the student otherwise

provided official notification to the school, in writing or orally, of his or her intent to

withdraw; (3) if the student ceases attendance without providing official notification to

the institution of his or her withdrawal, the midpoint of the payment period or, if

applicable, the period of enrollment; (4) if the institution determines that a student did not

begin the withdrawal process or otherwise notify the school of the intent to withdraw due

to illness, accident, grievous personal loss or other circumstances beyond the student’s

control, the date the institution determines is related to that circumstance; (5) if a student

does not return from an approved leave of absence, the date that the institution

determines the student began the leave of absence; or (6) if the student takes an

unapproved leave of absence, the date that the student began the leave of absence.

Notwithstanding the above, an institution that is not required to take attendance may use

as the withdrawal date, the last date of attendance at an academically related activity as

documented by the institution (34 CFR sections 668.22(c) and (d)).

An institution that is required to take attendance, or requires that attendance be taken on

only one specified day to meet a census reporting requirement, is not considered to take

attendance (34 CFR section 668.22(b)(3)(iv).

Calculation of the Amount of Title IV Assistance Earned

The amount of earned Title IV grant or loan assistance is calculated by determining the

percentage of Title IV grant or loan assistance that has been earned by the student and

applying that percentage to the total amount of Title IV grant or loan assistance that was

or could have been disbursed to the student for the payment period or period of

enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her

withdrawal date is after the completion of 60 percent of (1) the calendar days in the

payment period or period of enrollment for a program measured in credit hours, or (2) the

clock hours scheduled to be completed for the payment period or period of enrollment for

a program measured in clock hours (34 CFR section 668.22(e)(2)). Otherwise, the

percentage earned by the student is equal to the percentage (60 percent or less) of the

payment period or period of enrollment that was completed as of the student’s

withdrawal date. The percentage of Title IV grant or loan assistance that has not been

earned by the student is the complement of one of these calculations. Standard term-

based institutions must always use the payment period as the basis for the determination.

The unearned amount of Title IV assistance to be returned is calculated by subtracting the

amount of Title IV assistance earned by the student from the amount of Title IV aid that

was disbursed to the student as of the date of the institution’s determination that the

student withdrew (34 CFR section 668.22(e)).



Use of Payment Period or Period of Enrollment

The treatment of Title IV grant or loan funds if a student withdraws must be determined

on a payment period basis for a student who attended a standard term-based (semester,

trimester or quarter) educational program. The treatment of Title IV grant or loan funds

if a student withdraws may be determined on either a payment period basis or a period of

enrollment basis for a student who attended a non-term based or a nonstandard term-

based educational program. The institution must use the chosen period consistently for

all students in the program, except that an institution may make a separate selection of

payment period or period of enrollment for students that transfer to the institution or

reenter the institution for students who attend a non-term-based or nonstandard term-

based program (34 CFR section 668.22(e)(5)). An institution must use the payment

period that ends later to calculate a “Return of Title IV Funds” when a student withdraws

from a non-standard term credit hour program with terms that are not substantially equal

in length, and the student was disbursed or could have been disbursed Title IV aid under

more than one payment period definition (34 CFR section 668.22(e)(5)(iii)).

Percentage of Payment Period or Period of Enrollment Completed

The percentage of the payment period completed or period of enrollment completed is

determined in the case of a program that is measured in (1) credit hours, by dividing the

total number of calendar days in the payment period or period of enrollment into the

number of calendar days completed in that period as of the student’s withdrawal date; or

(2) clock hours, by dividing the total number of clock hours in the payment period or

period of enrollment into the number of clock hours scheduled to be completed as of the

student’s withdrawal date. The total number of calendar days in a payment or enrollment

period includes all days within the period, except that institutionally scheduled breaks of

at least 5 consecutive calendar days (including module programs that a student is not

required to attend for 5 consecutive calendar days) and days in which the student was on

an approved leave of absence are excluded from the total number of calendar days in a

payment period or period of enrollment and the number of calendar days completed in

that period (34 CFR section 668.22(f)).

Institution’s Return of Unearned Aid

The institution must return the lesser of (1) the total amount of unearned Title IV

assistance to be returned as described above, or (2) an amount equal to the total

institutional charges incurred by the student for the payment period or period of

enrollment multiplied by the percentage of Title IV grant or loan assistance that has not

been earned by the student. If, for a non-term program an institution chooses to calculate

the treatment of Title IV assistance on a payment period basis, but the institution charges

for a period that is longer than the payment period, “total institutional charges incurred by

the student for the payment period” is the greater of (1) the prorated amount of

institutional charges for the longer period, or (2) the amount of Title IV assistance

retained for institutional charges as of the student’s withdrawal date (34 CFR section

668.22(g)).



Student’s Return of Unearned Aid

The amount a student is responsible for returning is calculated by subtracting the amount

of unearned aid that the institution is required to return from the total amount of unearned

Title IV assistance to be returned. However, the student need only return 50 percent of

the total grant assistance that was disbursed (and that could have been disbursed) for the

payment period or period of enrollment. After the 50 percent rule is applied, a student

does not have to return an overpayment amount of $50 or less.

In addition, the Secretary may waive grant overpayments that students are required to

return if the students who withdrew were residing in, employed in, or attending an

institution located in an area where the President has declared that a major disaster exists

(34 CFR sections 668.22(g), 668.22(h)(3), and 668.22(h)(5)).

Allocation of Return of Title IV Funds

Returns of Title IV funds must be distributed in the order prescribed below. The

prescribed order must be followed regardless of the school’s agreements with other State

agencies or private agencies (34 CFR section 668.22(i)).

a. Unsubsidized Federal Direct Stafford Loans

b. Subsidized Federal Direct Stafford Loans

c. Federal Perkins Loan

d. Federal Direct PLUS

e. Federal Pell Grant

f. Federal Supplemental Educational Opportunity Grants

g. Teacher Education Assistance for College and Higher Education Grants

h. Iran and Afghanistan Service Grant

Timing of Return of Title IV Funds

Returns of Title IV funds are required to be deposited or transferred into the SFA account

or electronic fund transfers initiated to ED or the appropriate FFEL lender as soon as

possible, but no later than 45 days after the date the institution determines that the student

withdrew. Returns by check are late if the check is issued more than 45 days after the

institution determined the student withdrew or the date on the canceled check shows the

check was endorsed more than 60 days after the date the institution determined that the

student withdrew (34 CFR section 668.173(b)).



An institution must determine the withdrawal date for a student who withdraws without

providing notification to the institution no later than 30 days after the end of the earlier of

the (1) payment period or period of enrollment, (2) academic year in which the student

withdrew, or (3) educational program from which the student withdrew (34 CFR section

668.22(j)).

Compliance Requirements - Applicable for a Student Who Does Not Begin

Attendance

When a recipient of Title IV grant or loan assistance does not begin attendance at an

institution during a payment period or period of enrollment, all disbursed Title IV grant

and loan funds must be returned. The institution must determine which Title IV funds it

must return or if it has to notify the lender or the Secretary to issue a final demand letter

(34 CFR section 668.21).

Not beginning attendance

A student is considered to have not begun attendance in a payment period or period of

enrollment if the institution is unable to document the student’s attendance at any class

during the payment period or period of enrollment (34 CFR section 668.21(c)).

FPL, FSEOG, TEACH Grants, Pell Grant, and IASG program funds

The institution must return all FPL, FSEOG, TEACH Grants, Pell Grant, and IASG

program funds that were credited to the student’s account or disbursed directly to the

student for that payment period or period of enrollment (34 CFR section 668.21(a)(1)).

Direct Loan Funds

The institution must return all Direct Loan funds that were

a. Credited to the student’s account for that payment period or period of enrollment;

b. Payments made directly by or on behalf of the student to the institution for that

payment period or period of enrollment, up to the total amount of the loan funds

disbursed; or

c. Disbursed directly to the student if the institution knew that a student would not

begin attendance prior to disbursing the funds directly to the student for that

payment period or period of enrollment (e.g., the student notified the institution

that he or she would not attend, or the institution expelled the student).

For remaining amounts of Direct Loan funds disbursed directly to the student for the

payment period or period of enrollment (including funds disbursed directly to the student

by the lender for a study-abroad program or for a student enrolled in a foreign school),

the institution must immediately notify the lender or the Secretary, as appropriate, when

it becomes aware that the student will not or has not begun attendance so that the lender



or the Secretary will issue a final demand letter to the borrower in accordance with

34 CFR section 685.211 (34 CFR section 668.21(a)(2)).

Deadline for return of funds by the institution

The institution must return those funds for which it is responsible as soon as possible, but

no later than 30 days after the date that the institution becomes aware that the student will

not or has not begun attendance (34 CFR section 668.21(b)).

Timely return of funds by the institution

An institution returns Title IV funds timely if:

a. The institution deposits or transfers the funds into the bank account it maintains

under 34 CFR section 668.163 as soon as possible, but no later than 30 days after

the date that the institution becomes aware that the student will not or has not

begun attendance;

b. The institution initiates an EFT as soon as possible, but no later than 30 days after


begun attendance;

c. The institution initiates an electronic transaction, as soon as possible, but no later

than 30 days after the date that the institution becomes aware that the student will

not or has not begun attendance, that informs the lender to adjust the borrower’s

loan account for the amount returned; or

d. The institution issues a check as soon as possible, but no later than 30 days after


begun attendance; an institution does not satisfy this requirement if

(1) The institution’s records show that the check was issued more than 30

days after the date that the institution becomes aware that the student will

not or has not begun attendance; or

(2) The date on the cancelled check shows that the bank used by the Secretary

endorsed that check more than 45 days after the date that the institution

becomes aware that the student will not or has not begun attendance (34

CFR section 668.21(d)).

Audit Objectives - Determine whether the institution is making returns of Title IV funds

in the proper amount and in a timely manner and is applying the return of Title IV funds

to Federal programs as required.




a. Identify a sample of students who received Title IV assistance who withdrew,

dropped out, or never began attendance during the audit period. Review return of

Title IV funds determinations/calculations for conformity with Title IV

requirements and recalculate.

b. Trace the return of Title IV funds to disbursement and accounting records

(including canceled checks to ED and students) to verify that returned Title IV

funds were applied to programs in the required order and were timely. Ascertain

that within 45 days (or within 30 days for students that never began attendance) of

becoming aware that the student had withdrawn, deposits or transfers were made

into the Federal funds account, electronic transfers were initiated, or checks were

issued. For returns made by check, examine canceled check endorsements and

determine if the check was endorsed within the prescribed 60 days (or within 45

days for students that never began attendance).

c. For a sample of students who received Title IV assistance, for which no return of

Title IV funds were made, review academic and enrollment records (including

class attendance records if they are kept) to ascertain whether the students

sufficiently completed the payment or enrollment period to earn the Title IV funds

received. When doing this, for students who received all failing and/or all

incomplete grades, review records to ascertain whether the students had attended

the institution, or had attended but withdrawn.

5. Enrollment Reporting

Compliance Requirements - Under the Pell grant and ED loan programs, institutions

must complete and return within 15 days the Enrollment Reporting roster file [formerly

the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet

Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.

1845-0035). The institution determines how often it receives the Enrollment Reporting

roster file with the default set at a minimum of every 60 days. Once received, the

institution must update for changes in student status, report the date the enrollment status

was effective, enter the new anticipated completion date, and submit the changes

electronically through the batch method or the NSLDS website (FPL, 34 CFR section

674.19; Pell, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan,

34 CFR section 685.309). (Note: The automated processes are described in the NSLDS

Enrollment Reporting Guide, , which is available at

https://ifap.ed.gov/ifap/byNSLDSType.jsp?type=NSLDS%20User%20Documentation.

Institutions are responsible for timely reporting, whether they report directly or via a

third-party servicer. NSLDS will send a Late Enrollment Reporting notification

e-mail if no updates are received by batch or online within 22 days after the date the

roster was sent to the school. The Enrollment Reporting Summary Report (SCHER1) on

the NSLDS website can be created at the request of the institution. It shows the dates the

roster files were sent and returned, the number of errors, date and number of online

https://ifap.ed.gov/ifap/byNSLDSType.jsp?type=NSLDS%20User%20Documentation



updates, and the number of late enrollment reporting notifications sent for overdue

Enrollment Reporting rosters.

A student’s enrollment status determines eligibility for in-school status, deferment, and

grace periods, as well as for the payment of interest subsidies to FFEL Program loan

holders by ED. Enrollment Reporting in a timely and accurate manner is critical for

effective management of the programs. Enrollment information must be reported within

30 days whenever attendance changes for students, unless a roster will be submitted

within 60 days. These changes include reductions or increases in attendance levels,

withdrawals, graduations, or approved leaves-of-absence.

ED issued a Dear Colleague Letter March 30, 2012 (GEN-12-06) that included

enhancements to NSLDS Enrollment Reporting Process and reminders to institutions

regarding their responsibilities for NSLDS Enrollment Reporting which are available at

http://www.ifap.ed.gov/dpcletters/GEN1206.html. ED also issued a Dear Colleague

Letter, dated April 14, 2014 (GEN-14-07), explaining changes to NSLDS Enrollment

Reporting Process, which include changes to reporting of additional data, reporting at the

academic program level, and more frequent reporting. GEN 14-07 is available at

http://www.ifap.ed.gov/dpcletters/GEN1407.html.

Audit Objective – Determine whether the institution is promptly notifying ED, guaranty

agencies, or lenders, as appropriate, and NSLDS of changes in student status in a timely

and accurate manner.


a. Review, evaluate, and document procedures for updating student status for Pell

grants and ED loan recipients, including how often the institution performs the

updates.

b. Determine if the school is meeting reporting requirements by having the school

access the NSLDS website and create the SCHER1. Compare the dates the roster

files were sent to the return dates to verify that the school returned the roster files

within 15 days, and report any discrepancies related to the timeliness of the roster

files.

c. Test the accuracy and timeliness of the enrollment data certification by selecting a

sample of students from the institution's records that had a reduction or increase in

attendance levels, graduated, withdrew, dropped out, or enrolled but never

attended during the audit period. Compare the data in the NSLDS Enrollment

Detail to the students’ academic files, and verify that the institution is reporting

accurate attendance changes for students within 30 days (unless the roster file will

be submitted within 60 days) and report discrepancies.





6. Student Loan Repayments (FPL, HPSL/PCL/LDS and NSL, and NFLP)

Compliance Requirements - FPL loans, and HPSL/PCL/LDS and NSL loans made prior

to November 13, 1998, including accrued interest, are repayable in equal or graduated

periodic installments in amounts calculated on the basis of a 10-year repayment period.

For HPSL/PCL/LDS loans the repayment period is not less than 10 and not more than 25

years, at the discretion of the institution. For NSL loans after November 13, 1998, the

10-year repayment period may be extended for 10 years for any student borrower who,

during the repayment period failed to make consecutive payments and who, during the

last 12 months of the repayment period, has made at least 12 consecutive payments

(42 USC 292r(c) and 297b(b)(8) (Sections 722(c) and 836(b)(8) of PHS Act); Pub. L. No.

105-392, Sections 133(a)(2) and 134(a)(3)). Except as required in 42 CFR section

57.210(a), a repayment of a HPSL/PCL/LDS loan must begin one year after the student

ceases to be a full-time student. For a NSL loan, repayment must begin 9 months after

the student ceases to be a full-time or half-time student, except as required in 42 CFR

section 57.310(a). For a FPL loan, the institution must establish a repayment plan. The

repayment period begins after an initial grace period of either 6 months or 9 months after

the student ceases to be at least a half-time student at an institution of higher education,

depending on when the loan was made (34 CFR section 674.31(b)(2)).

For NFLP, loans are repayable in equal or graduated periodic installments in amounts

calculated on the basis of a 10-year repayment period. Following graduation from the

nursing program, up to 85 percent of the principal and interest of an NFLP loan can be

cancelled if the student borrower serves as full-time nurse faculty for 4 years. For this

program, “full-time” is defined as either (1) a full-time faculty member at an accredited

school of nursing; or (2) a part-time faculty member at an accredited school of nursing, in

combination with another part-time faculty position or part-time clinical preceptor

position affiliated with an accredited school of nursing that, together, equate to full-time

employment. The loan cancellation over the 4-year period is as follows: (1) the school

will cancel 20 percent of the principal and interest on the NFLP loan, as determined on

the first day of employment, upon completion by the borrower of each of the first,

second, and third years of full time employment as a faculty member in a school of

nursing; and (2) the school will cancel 25 percent of the principal and interest on the

NFLP loan, as determined on the first day of employment, upon completion of the fourth

year of full-time employment as a faculty member in a school of nursing. Repayment on

the remaining 15 percent of the loan balance is postponed during the cancellation period.

NFLP loans are repayable and/or cancelled over a 10-year repayment period. NFLP

loans accrue interest at a rate of three percent per annum for loan recipients who establish

employment as full-time nurse faculty (Funding Opportunity Announcements

https://bhw.hrsa.gov/fundingopportunities/default.aspx?id=bd03570b-3eb6-4a77-a1e3-

4326ce292907).

FPL borrowers may be eligible for loan deferments under certain circumstances.

Examples of when loan payments may be deferred are when the borrower is enrolled at

least half-time at an eligible institution; enrolled in a graduate fellowship program;

engaged in graduate or post-graduate fellowship-supported study outside the United

States; or enrolled in a rehabilitation training program. A borrower of FPL may qualify

https://bhw.hrsa.gov/fundingopportunities/default.aspx?id=bd03570b-3eb6-4a77-a1e3-4326ce292907

https://bhw.hrsa.gov/fundingopportunities/default.aspx?id=bd03570b-3eb6-4a77-a1e3-4326ce292907



for a deferment if the borrower is seeking and unable to find full-time employment or is

suffering an economic hardship. An FPL borrower also may qualify for a deferment for

certain qualifying military service. In addition to these deferments, FPL borrowers who

received their loans prior to July 1, 1993, may qualify for a variety of deferments. A

borrower may receive a deferment for a period when the borrower is engaged in service

that would qualify for a cancellation (34 CFR sections 674.34, 674.35, 674.36, and

674.37).

To qualify for a deferment of an FPL loan, the borrower is required to submit to the

institution to which the loan is owed a request for the deferment, with documentation

required by the institution, by the date established by the institution. A school may grant

a deferment request if the school can confirm that the borrower has received a deferment

on another FPL, FFEL, or Direct Loan for the same reason and the same time period. For

an in-school deferment, the institution may grant the deferment based on student

enrollment information showing that a borrower is enrolled as a regular student on at

least a half-time basis, if the institution notifies the borrower of the deferment and of the

borrower’s option to cancel the deferment and continue paying on the loan (34 CFR

section 674.38).

FPL loans may be canceled based on qualifying employment (1) as a teacher at certain

schools or in specified fields; (2) as a nurse or medical technician; (3) in a public or

private non-profit child or family service agency; (4) as a professional provider of early

intervention services; (5) as a firefighter; (6) as a faculty member in a Tribal College or

University; (7) as a librarian or speech pathologist with a master’s degree; or (8) in an

early childhood education program. FPL loans may be cancelled based on qualifying

service as a law enforcement or corrections officer or for qualifying military service.

FPL loans may be cancelled for service as volunteer in the Peace Corps or in Americorps

Volunteers in Service to America. Cancellation rates (amount of loan that is canceled for

each year of qualifying service) for FPL loans vary, depending on the criteria. Specific

requirements for cancellation vary (34 CFR sections 674.51 through 674.60). FPL

cancellations have not been reimbursed to institutions since the 2008-2009 award year.

Although FPL service cancellations are not funded, schools must still offer and apply

applicable cancellations to borrowers (ED memorandum on Perkins Cancellations which

is available at

(http://ifap.ed.gov/eannouncements/051314FederalPerkinsLoanServiceCancellationReim

bursement20122013.html).

To qualify for a cancellation of an FPL loan, the borrower is required to submit to the

institution to which the loan is owed a written request for the cancellation, with

documentation required by the institution, by the date established by the institution (34

CFR section 674.52).

An FPL loan may be discharged due to school closure, bankruptcy of the borrower, or the

death or total and permanent disability of the borrower (34 CFR sections 674.33(g),

674.49, and 674.61).

http://ifap.ed.gov/eannouncements/051314FederalPerkinsLoanServiceCancellationReimbursement20122013.html

http://ifap.ed.gov/eannouncements/051314FederalPerkinsLoanServiceCancellationReimbursement20122013.html



Loans under the HPSL/PCL/LDS, NSL, and NFLP programs may be cancelled only in

the event that the borrower dies or becomes disabled.

(FPL, 34 CFR sections 674.33 through 674.40, and 674.51 through 674.62;

HPSL/PCL/LDS; 42 CFR sections 57.211 and 57.213a; NSL; 42 CFR sections 57.311

and 57.313a; and NFLPAdministrative Guidelines, Disability and Death

(https://bhw.hrsa.gov/loansscholarships/schoolbasedloans/nflp)).

Institutions must exercise due care and diligence in the collection of loans

(HPSL/PCL/LDS, NSL, and NFLP, 42 CFR sections 57.210(b) and 57.310(b), and NFLP

Program Guidance, Institutional Responsibility in Repayment Process, respectively). For

the FPL, such due diligence procedures include the following:

a. A requirement to conduct an exit interview with the borrower before he or she

leaves the institution and to contact the borrower a minimum of three times during

the initial grace period for loans with 9-month grace periods or two times for

loans with 6-month grace periods (34 CFR section 674.42).

b. Specific billing procedures to notify borrowers of overdue payments and to

demand overdue amounts (34 CFR section 674.43).

c. Specific collection procedures to recover amounts from defaulted borrowers who

do not respond satisfactorily to demands routinely made as part of the institution’s

billing procedures, including litigation procedures (34 CFR section 674.45).

Audit Objectives - Determine whether institutions are processing deferment and

cancellation requests and servicing loans as required.


Note: Many institutions engage third-party servicers for billing, collection, and

processing deferment and cancellation requests. Although these institutions remain

responsible for compliance, auditors of these institutions may exclude the audit

procedures below for the compliance requirements performed by a third-party servicer.

a. Select a sample of loans that entered repayment during the audit period and

review loan records to verify that the conversion to repayment was timely, and

that a repayment plan was established.

b. Review the institution’s requirements for applying for and documenting eligibility

for loan deferments and cancellations. Select a sample of loans that were deferred

or cancelled during the audit period and review documentation to ascertain

whether the deferments or cancellations were adequately supported.

c. Select a sample of loans that have defaulted during the year and review loan

records to ascertain if the required interviews, contacts, billing procedures and

collection procedures were carried out.

http://bhw.hrsa.gov/loansscholarships/schoolbasedloans/nflp



7. Federal Work-Study Agreements

Compliance Requirement – FWS students may be employed by the institution, a

Federal, State, or local agency, a private not-for-profit organization, or a private for-profit

organization but the employment must not (1) impair existing service contracts;

(2) displace employees; (3) fill jobs that are vacant because the employer’s regular

employees are on strike; or (4) involve the construction, operation, or maintenance of any

part of a facility used or to be used for religious worship or sectarian instruction. The

institution must enter into a written agreement with any agency or organization providing

employment under the FWS program (34 CFR sections 675.20 through 675.23).

Audit Objective – Determine whether written agreements with non-institutional

employers are made as required.

Suggested Audit Procedure

Select a sample of participating students and ascertain if written agreements with the non-

institutional employers were executed.

8. Borrower Data Transmission and Reconciliation (Direct Loan)

Compliance Requirement – Institutions must report all loan disbursements and submit

required records to the Direct Loan Servicing System (DLSS) via the COD within

15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides

institutions with a School Account Statement (SAS) data file which consists of a Cash

Summary, Cash Detail, and (optional at the request of the school) Loan Detail records.

The school is required to reconcile these files to the institution’s financial records. Since

up to three Direct Loan program years may be open at any given time, schools may

receive three SAS data files each month (34 CFR sections 685.102(b), 685.301, and 303).

(Note: An electronic announcement dated December 21, 2017 describes the

reconciliation process and is available at:

https://ifap.ed.gov/eannouncements/122117WilliamDFordFedDirectLoanPrgmReconcilia

tion.html.)

Audit Objectives - Determine whether the institution reconciled SAS data files to

institution records each month. Determine whether dates and amounts of disbursements

to borrowers recorded in the DLSS are supported by the institution’s records on

individual borrowers.


a. Test a sample of the SAS and ascertain that reconciliations are being performed.

Instructions for obtaining specific borrower information are available at

http://www.ed.gov/about/offices/list/oig/nonfed/sfa.html.

b. Test a sample of borrowers to verify that disbursement dates and amounts in the

DLSS are supported by the institution’s records.

http://www.ed.gov/about/offices/list/oig/nonfed/sfa.html



9. Institutional Eligibility


a. An institution is not eligible to participate in Title IV programs if for the award

year (year ending June 30) that ended during the institution’s fiscal year

(34 CFR section 600.7):

(1) More than 50 percent of its courses were correspondence courses;

(2) 50 percent or more of its regular students (i.e., students enrolled for the

purpose of obtaining a degree, certificate or diploma) were enrolled in

correspondence courses;

(3) 25 percent or more of its regular students were incarcerated;

(4) More than 50 percent of its regular students were enrolled as “ability-to

benefit students,” i.e., without a high school diploma, the recognized

equivalent and the institution did not provide a 4- or 2-year program for

which it awards a bachelor’s or associate degree, respectively.

(Note: “Correspondence course” is defined in 34 CFR section 600.2.)

b. The institution is prohibited for paying any commission, bonus, or other incentive

payment based, in any part, directly or indirectly, upon success in securing

enrollments or the award of financial aid, to any person or entity engaged in any

student recruiting or admission activities, or in making decisions regarding the

awarding of Title IV, HEA program funds. This limitation does not apply to the

recruitment of foreign students residing in foreign countries who are not eligible

to receive Title IV, HEA program funds (34 CFR section 668.14(b)(22)(i)). Title

34 CFR section 668.14(b)(22)(ii) describes specific activities and arrangements

that an institution may carry out without violating this regulatory prohibition. It

also contains a provision applying this same prohibition to any entity or person

engaged by the institution to deliver services to it (34 CFR section

668.14(b)(22)(iii)(C)). The auditor should refer to the specific text of these

regulations when auditing this compliance requirement.

c. Institutions must establish and publish reasonable standards for measuring

whether eligible students are maintaining satisfactory progress in their educational

program. The institution’s standards are reasonable if the standards (34 CFR

sections 668.16(e) and 668.34) do the following:

(1) Are the same as or stricter than the standards for a student enrolled in the

same program that is not receiving Title IV student financial aid;

(2) Provide for consistent application of standards to all students within

categories of students and educational programs;



(3) Provide for the student’s academic progress to be evaluated

(a) at the end of each payment period if the educational program is

either one academic year in length or shorter than an academic

year; or

(b) for all other educational programs, at the end of each payment

period or at least annually to correspond with the end of a payment

period;

(4) Include a qualitative component, which generally consists of grades that

are measurable against a norm, and a quantitative component that consists

of a maximum time frame for completion of the educational program.

That time frame must, for an undergraduate program, be no longer than

150 percent of the published length of the educational program;

(5) Provide a policy that, if at the time of each evaluation, the student has not

achieved the required GPA or is not successfully completing their program

of study at the required pace, they no longer are eligible for Title IV aid;

(6) Provide specific procedures for disbursements to students on financial aid

warning status or financial aid probation status;

(7) If the institution permits the student to appeal a determination, provide

specific procedures how the student may reestablish eligibility to receive

Title IV; basis on which a student may file an appeal; and information that

the student must submit regarding why they failed satisfactory academic

progress and how they have changed that will now allow the student to

make satisfactory academic progress at the next evaluation;

(8) If the institution does not permit the student to appeal a determination,

provide a policy for a student to reestablish their eligibility to receive Title

IV assistance; and

(9) Provide notification to the students of their results of an evaluation that

impacts their eligibility for Title IV.

d. Each institution’s most recent Eligibility and Certification Approval Report

(ECAR) lists the institution’s main campus and any additional approved locations.

For any other locations at which a school offers 50 percent or more of an eligible

program during the audit period, the institution must either submit an application

for approval of that location or notify ED of that location (34 CFR sections

600.20(c) and 600.21(a)(3)).

Audit Objective – Determine whether the institution meets the above institutional

eligibility requirements as applicable.




a. For the award year that ended during the fiscal year, obtain from the institution its

calculation of its award year institutional eligibility ratios of correspondence

courses, students enrolled in correspondence courses, and incarcerated and

“ability-to-benefit students.” Ascertain the proper classification and completeness

of data and accuracy of the calculations.

b. Ascertain the methodologies used to recruit, admit, and enroll students, and award

Federal financial aid, e.g., using employees, employment contracts, contracting

with third parties or Internet providers, or combinations of these or other methods.

(1) For institutional employees who recruit, admit, and enroll students, and

award federal financial aid, evaluate the compensation plans and all forms

of compensation to the employees, to ensure that the institution is in

compliance with the regulatory requirements.

(2) For contracts with third parties who recruit, admit, and enroll students, and

award financial aid for the institution, read the contracts to identify any

provisions indicating that third parties were to act in a manner contrary to

regulations pertaining to paying commissions, bonuses or other incentive

payments. Also, review payments made to third parties to determine if

payments were made in excess of contractual provisions. Determine if

excess payments were made to cover commissions, bonuses, or other

incentive payments, made by the third-party servicer contrary to the

regulations.

c. Ascertain from a review of the institution’s published satisfactory progress

standards that all required elements are included in the standards and, from the

test of students sampled, ensure the students are making satisfactory academic

progress, and if not, the regulations are followed.

d. Obtain the ECAR that was in effect for the audit period and identify the main

campus and any additional locations. Ascertain if the institution is offering more

than 50 percent of an eligible program at any locations not on the ECAR. If so,

determine if the institution notified ED of the additional location or submitted an

application for approval of the additional location.

10. Zone Alternative (Not applicable to public entities)

Compliance Requirements – For an institution to participate in any Title IV, HEA

program, the institution must be financially responsible (34 CFR section 668.171(a)).

(Note: Institutions become ineligible to participate in the Federal student aid programs if

they have filed bankruptcy (34 CFR section 600.7(a)(2).) Limited participation under

provisional certification from ED may be available to institutions that do not meet the

financial responsibility standards, which also imposed the “zone alternative” requirement

(34 CFR section 668.175(f)).



Under the zone alternative, an institution is required to make disbursements to students

and parents under either the cash monitoring or reimbursement payment method (34 CFR

section 668.175(d)(2)(i)). (See III.C, “Cash Management,” above.) The institution must

also notify the Secretary by certified mail, electronic, or facsimile transmission no later

than 10 days after one of the following events occurs (34 CFR section 668.175(d)(3)(i)):

a. Any adverse action, including a probation or similar action, taken against the

institution by its accrediting agency;

b. Any event that causes the institution, or related entity as defined in the Financial

Accounting Standards Board (FASB) Accounting Standards Codification (ASC)

850, Related Party Disclosures, to realize any liability that was noted as a

contingent liability in the institution’s or related entity’s most recent audited

financial statement;

c. Any violation by the institution of any loan agreement;

d. Any failure of the institution to make a payment in accordance with its debt

obligations that results in a creditor filing suit to recover funds under those

obligations or includes the institution filing for bankruptcy;

e. Any withdrawal of owner’s equity from the institution by any means, including

by declaring a dividend; or

f. Any extraordinary losses, as defined in accordance with FASB, ASC 225-20

(previously Accounting Principles Board (APB) Opinion No. 30) (34 CFR

sections 600.7(h) and 668.175(d)(2)(ii)).

Audit Objectives – Determine whether, for the non-profit institution participating in

Title IV, HEA programs under the zone alternative, ED was timely notified if any of the

events identified in 34 CFR section 668.175(d)(2)(ii) occurred, and disbursements to

students and parents complied with the requirements of the cash monitoring or

reimbursement payment methods.


a. Obtain a written representation from management as to whether the institution is

participating under the “zone alternative.” (If it is not, no further procedures

relating to this section must be performed. If it is, additional audit procedures

must be performed – see suggested procedures below.)

b. Review the institution’s disbursement methods and assess whether the institution

complied with the cash monitoring or reimbursement method when making

disbursements to students and parents.

c. Obtain a written representation from management as to whether any of the events

specified at 34 CFR section 668.175(d)(2)(ii) occurred and, if so, whether they

notified ED within 10 days in the required manner.



d. Review copies of correspondence received by accrediting agencies for evidence

of the occurrence of any of the events specified at 34 CFR section

668.175(d)(2)(ii), including probation or similar action.

e. Obtain a representation from management as to whether, to their knowledge, any

legal proceedings have been initiated against the institution for any violation of

any loan agreements or any failure to pay creditors.

f. Include in your inquiry to the lawyer regarding litigation, claims, and

assessments, a request for any information relating to any legal proceedings

against the institution for any violation of any loan agreements or any failure to

pay creditors.

g. Ascertain whether any contingent liabilities for the prior fiscal year have been

realized.

h. Review accounting records for evidence of withdrawal of owner’s equity, by any

means, including declaring a dividend.

i. Review accounting records for evidence of extraordinary losses.

11. Written Arrangements with Another Institution, Consortium, or

Organization to Provide Educational Programs

Compliance Requirements – An eligible institution may enter into a written

arrangement with another eligible institution (or a consortium of eligible institutions)

under which the other institution (or consortium) provides all or part of the educational

program, if the program(s) provided by the other eligible institution (or consortium

members) is (are) otherwise eligible.

If an eligible institution enters into a written arrangement with an institution or

organization that is not an eligible institution under which the ineligible institution or

organization provides part of the educational program of students enrolled in the eligible

institution, that educational program is considered to be an eligible program if it

otherwise satisfies the requirements for an eligible program and if the ineligible

institution or organization has not

a. had its eligibility to participate in the SFA programs terminated by ED;

b. voluntarily withdrawn from participation in the SFA programs under a

termination, show-cause, suspension, or similar type of proceeding initiated by

the institution’s State licensing agency, accrediting agency, guarantor, or ED;

c. had its certification to participate in Title IV revoked by ED; or

d. had its application for certification or recertification to participate in Title IV

denied by ED.



If an institution enters into a written agreement with an ineligible institution or

organization, the ineligible institution or organization may not provide more than 25

percent of the educational program. However, the ineligible institution or organization

may provide more than 25 percent, but less than 50 percent, of the educational program,

if

a. the eligible institution and the ineligible institution or organization are not owned

or controlled by the same individual, partnership or corporation; and

b. the eligible institution’s accrediting agency [or if the institution is a public

postsecondary vocational educational institution, the regulating State agency

designated per 34 CFR part 603] has specifically determined that the institution’s

arrangements meet the agency’s standards for contracting for educational services

(34 CFR section 668.5(c)).

Audit Objective – Determine whether educational programs that are contracted out to

ineligible institutions, consortiums, or organizations to provide educational programs to

its students do not exceed regulatory limits.


a. Ascertain if the institution has entered into an agreement for its students to

complete part of their educational program at another institution, consortium, or

organization.

b. If so, ascertain that the institution determined whether or not the contracted

institution, consortium, or organization was an eligible institution.

c. If an agreement was entered into with an ineligible institution or organization,

verify the percentage of the educational program provided by the contracted

institution, consortium or organization.

d. If an ineligible institution or organization is providing more than 25 percent, but

less than 50 percent of the program, ascertain that the eligible and ineligible

institution or organization are not owned or controlled by the same individual,

partnership, or corporation; and that the eligible institution’s accrediting agency,

or, if the institution is a public postsecondary vocational educational institution,

the appropriate State agency specifically determined that the institution’s

arrangements meet the agency’s standards for contracting for educational

services.

12. Short Term Programs at Postsecondary Vocational Institutions

Compliance Requirements – For the Direct Loan Program, short-term eligible programs

at a postsecondary vocational institution (as defined at 34 CFR section 600.6(a)) must be

between 300 - 599 clock hours. They must have been provided for at least one year and

must have a substantiated completion and placement rate of at least 70 percent for the

most recently completed award year (34 CFR sections 668.8(d)(2)(ii), 668.8(d)(3)(ii), and



668.8(e)). Completion and placement rates must be calculated in accordance with 34

CFR sections 668.8(f) and (g).

An institution must have documentation supporting its placement rates for each student

showing that the student obtained gainful employment in the recognized occupation for

which he or she was trained or in a related comparable recognized occupation. Examples

of satisfactory documentation of a student’s gainful employment include, but are not

limited to, (1) a written statement from the student’s employer, (2) signed copies of State

or Federal income tax forms, or (3) written evidence of payments of Social Security taxes

(34 CFR section 668.8(g)(2)).

Audit Objective – If there are eligible short-term programs for which students received

loans under the Direct Loan program, determine whether the institution’s calculation of

its completion and placement rates was in accordance with ED requirements.


a. Review the completion and placement calculation to determine that the

calculations were computed as specified in 34 CFR sections 668.8(f) and (g).

b. Trace the students used in each of the calculations to records that support the

numbers indicated.

c. Randomly select samples of students counted in the completion and placement

components of the calculations and trace to records that support their inclusion in

that component of the calculation, including records supporting students’ gainful

employment.

13. Federal Perkins Loan Liquidation

Compliance Requirements – For an institution that decided to stop participating in the

Federal Perkins Loan program (Perkins) (CFDA 84.038), the institution is responsible for

returning any unspent funds (34 CFR section 668.14(b)(25)). The institution must

perform the end-of-participation procedures in which it must (a) notify ED of the intent to

stop participating in Perkins (34 CFR section 668.26(b)(1)); (b) inform ED of how the

institution will provide for the collection of any outstanding loans made under the

program (34 CFR section 668.26(b)(4)); (c) purchase any outstanding loans left in its

Perkins portfolios or assign them to ED (34 CFR sections 674.8(d), 674.17(a)(2), and

674.45(d)(2)); and (d) maintain program and fiscal records of all Perkins funds since the

most recent Fiscal Operations Report (FISAP) was submitted, and reconcile this

information at least monthly (34 CFR section 674.19(d)). The FISAP form is available at

https://ifap.ed.gov/ifap/fisap_form.jsp. Additional information can be found in the

Federal Perkins Loan Program Assignment and Liquidation Guide, available at

https://ifap.ed.gov/cbpmaterials/attachments/PerkinsAssignmentandLiquidationGuide.pdf

Audit Objective – Determine whether the institution ceasing to participate in the Perkins

loan program has properly performed end-of-participation procedures.

https://ifap.ed.gov/ifap/fisap_form.jsp

https://ifap.ed.gov/cbpmaterials/attachments/PerkinsAssignmentandLiquidationGuide.pdf




a. Review, evaluate, and document procedures that the institution used to notify ED

of its intent to liquidate its Perkins loan portfolios.

b. If the institution has completed the liquidation of its Perkins loan portfolio,

ascertain that the institution has either purchased or assigned to ED any Perkins

loans with outstanding balances.

c. If the process of liquidating outstanding loans has not been completed, verify

that the institution has informed ED of how the institution will provide for the

collection of the outstanding loans made under the program.

d. Ascertain that the institution, as part of its procedures for maintaining program

and fiscal records for all transactions that occurred after the most recent FISAP

was filed, reconciled the following information:

(1) All loans for the total number of borrowers that make up the portfolio

have been accounted for, including retired loans (including loans

purchased) and loans assigned to ED (including validation of the

computed accumulated interest charged on the loans);

(2) Service cancellation data that will be counted in Part III, Fiscal Report

(Section A, lines 7-25 and 35-52), and all of the data that will be in Part

III, Cumulative Repayment Information (Section C, lines 1.1 – 5.4);

(3) The Federal Capital Contribution (FCC) that will be reported at the end of

fiscal year under Fund Activity (Section B, lines 1-4);

(4) The Institutional Capital Contribution (ICC) that will be reported at the

end of fiscal year under Fund Activity (Section B, line 6); and

(5) Overall cash-on-hand or excess cash amounts (this overall cash-on-hand

amount would include payment to the Perkins fund for any loans the

school may have purchased) (Section A, Line 1.1).

e. If the liquidation process is complete, validate that the distributional shares of the

final capital distribution are calculated using the Over-time Calculation provided

in page 9 of the Perkins Liquidation Procedures and that the Federal portion is

returned to the U. S. Treasury.



IV. OTHER INFORMATION

All Pell Payment Data for an award year must be submitted by September 30 after the award

year. Adjustments for Pell grants not claimed by September 30 can be made if the first audit

report for the period in which the unclaimed Pell grants were made contains a finding that the

institution made proper Pell awards for which it has not received either reimbursement or credit.

Dear Colleague Letter (P-97-2) provides instructions to institutions for reporting the Pell

adjustments and describes the auditor’s responsibilities. (This information is provided to alert

auditors that their clients may request them to perform such additional audit work in conjunction

with the single audit, in order to claim Pell adjustments. Unless engaged by a client to do this

additional work, it is not otherwise required.)

Part 4 of the Compliance Supplement includes requirements for use by auditors when auditing

Guaranty Agencies and Lenders under the FFEL Program (CFDA 84.032). Part 4 requirements,

rather than this section, should be used when auditing the FFEL program at guaranty agencies

and lenders that are not schools. See below for requirements for schools that are lenders.

Some “statewide” entities are defined to include a guaranty agency and/or governmental lender

under the FFEL Program (CFDA 84.032). For such entities, Part 4 should be used to identify

pertinent compliance requirements. Auditors for such entities with large loan and loan guarantee

programs must consider the provision of 2 CFR section 200.518(b)(3) in determining major

programs. When those programs are determined to be major programs, coverage of the FFEL

program for a guaranty agency and/or a lender should be identified and reported on separately

and listed as a major program in the Summary of Auditor’s Results section of the Schedule of

Findings and Questioned Costs. In such cases, refer to the program as “CFDA 84.032 - FFEL -

Guaranty Agencies” and/or “CFDA 84.032- FFEL - Lenders”.

If the SFA Cluster was selected as a major Federal program for a school that is also a lender

under the FFEL program, the auditor must also include in the audit coverage work sufficient to

render an opinion, as part of the opinion on the SFA Cluster, on the school’s compliance with the

lender compliance requirements set forth in the Part 4 section for CFDA 84.032 for Lenders.

Audit documentation must demonstrate sufficient coverage of those compliance requirements to

support that requirement, as well as the compliance requirements set forth in the SFA Cluster.

When the SFA Cluster is audited for a school that is a lender, the major program should be listed

as a major program in the Summary of Auditor’s Results section of the Schedule of Findings and

Questioned Costs as “SFA Cluster (including CFDA 84.032 FFEL - Lenders).”

For schools that are lenders, if the SFA Cluster is not selected as a major program, CFDA 84.032

must be covered as a separate major program using the Part 4 section for CFDA 84.032 for

Lenders. In such cases, the major program should be listed in the Summary of Auditor’s Results

section of the Schedule of Findings and Questioned Costs as “CFDA 84.032 - FFEL - Lenders.”



APPENDIX A


STUDENT ELIGIBILITY COMPLIANCE REQUIREMENTS

Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

1.

A regular student enrolled or

accepted for enrollment in an eligible

program (34 CFR sections 600.2,

668.32(a)(1)(i), 690.75, 675.9, 676.9,

674.9, 685.200, 20 USC 1070h; 42

CFR sections 57.206(a) and 57.306(a), 42 USC 293a(d)(2))

x x x x x x x x x x

2.

U.S. Citizen, National, or provides

evidence from the U.S. Citizenship

and Immigration Services that he or

she is a permanent resident or in the

U.S. with the intention of becoming a

citizen or permanent resident. (34

CFR sections 668.32(d), 668.33(a),

690.75, 675.9, 676.9, 674.9, 685.200,

and 20 USC 1070h) and, for

HPL/PCL/LDS, an alien lawfully

admitted for permanent residence in

the U.S. or a citizen of the

Commonwealth of the Northern

Mariana Islands, the Republic of

Palau, the Republic of the Marshall

Islands, or of the Federated States of

Micronesia (42 CFR sections 57.206(a) and 57.306(a))

x x x x x x x x x x

3.

Has financial need and total awards

do not exceed need (34 CFR

675.9(c), 676.9(c), 674.9(c),

685.200(a)(2)(i), 20 USC 1070a, 42

CFR sections 57.206(b) and

57.306(b); 42 USC 293a(d)(2)); 42 USC 297n-1(c)(2))

x x x x x1 x x x

4.

Does not owe a refund on a grant

awarded under the Federal Pell Grant

or FSEOG programs, or Federal

Perkins loan overpayment (34 CFR

sections 668.32(g)(4), 690.75, 675.9,

676.9, 674.9, 685.200, 20 USC

1070h; 42 CFR sections 57.206 and

x x x x x x x

1 Does not always apply to unsubsidized loans and parent loans.



Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

57.306)

5.

Not in default on any student loans

(34 CFR sections 668.32(g)(1),

690.75, 675.9, 676.9, 674.9, 685.200,

20 USC 1070h; 42 CFR sections

57.206 and 57.306)

x x x x x x x x x

6.

Has not obtained loan amounts that

exceed annual or aggregate loan limits (34 CFR section 668.32(g)(2))

x x x x x x x x

7.

Does not have property subject to a

judgment lien for a debt owed to the

United States (34 CFR section

668.32(g)(3))

x x x x x x x

8.

Must maintain good standing, or

satisfactory progress (34 CFR

sections 668.16, 668.32(f), 668.34,

690.75, 675.9, 676.9, 674.9, 685.200,

20 USC 1070h; 42 CFR section

57.306; 42 USC 293a(d)(2))

x x x x x x x x x x

9.

Has registered under Section 3 of the

Military Selective Service Act (34

CFR sections 668.32(j), 668.37,

690.75, 675.9, 676.9, 674.9,

685.200,20 USC 1070h; 42 CFR

section, 57.206(a)(1)(iv))

x x x x x x x x

10.

Has a valid Social Security Number

(34 CFR sections 668.32(i), 690.75,

675.9, 676.9, 674.9, 685.200, 20 USC 1070h)

x x x x x x x

11.

Has a high school diploma, its

recognized equivalent, or another

indication of high school completion

status as documented in 34 CFR

668.32(e) (34 CFR sections

668.32(e), 690.75, 675.9, 676.9,

674.9, 685.200, 20 USC 1070h)

x x x x x x x

12.

Not been convicted of an offense

involving the possession or sale of

illegal drugs (34 CFR sections

668.32(l), 668.40, 20 USC 1070h)

x x x x x x x

13.

Is not enrolled in either an elementary

or secondary school (34 CFR section 668.32(b))

x x x x x x x

14. In the case of a student who has been

convicted of, or has pled nolo x x x x x x x



Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

contendere or guilty to, a crime

involving Title IV funds, has

completed the repayment of such

assistance (34 CFR section

668.32(m))

15.

For an undergraduate student, has not

completed coursework for a first

baccalaureate (34 CFR section 668.32(c))

x x x x

16.

An undergraduate student has

received for award year, a SAR or

determination of eligibility or

ineligibility for a Federal Pell Grant

(34 CFR sections 674.9(d),

685.200(a)(1)(iii), 690.75, 20 USC

1070h)

x x x x

17.

Is enrolled or accepted for enrollment

as an undergraduate student at the

institution (34 CFR sections 676.9(b), 690.75(a)(2))

x x

18. Is not incarcerated (34 CFR sections

668.32(c)(2)(ii) and (c)(3)) x2 x x

19.

If the student is not a regular student

enrolled or accepted for enrollment in

an eligible program (see item 1

above), the student is enrolled in a

course of study necessary for

enrollment in an eligible program for

not longer than one 12-month period (34 CFR section 668.32(a)(1)(ii))

x

20.

If the student is not a regular student

enrolled or accepted for enrollment in

an eligible program (see item 1

above), the student is enrolled or

accepted for enrollment as at least a

half-time student at an eligible

institution in a program necessary for

a professional credential or

certification from a State that is

required for employment as a teacher

in an elementary or secondary school

in that State (34 CFR section

x x x

2 Students incarcerated in Federal and State penal institutions are not eligible for Pell Grants, but those incarcerated in local penal

institutions are eligible.



Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

668.32(a)(1)(iii))

21.

Is enrolled or accepted for enrollment

as an undergraduate, graduate, or

professional student at the institution,

(34 CFR sections 674.9(b), 675.9(b),

and 685.101(b))

x x3 x

22

Is enrolled or accepted for

enrollment, on at least a half-time

basis in a school that participates in

the Direct Loan Program (34 CFR

sections 668.32(a)(2), 685.200(a)(1)(i))

x

23.

In the case of a first-time borrower,

has not met or exceeded the

limitations on the receipt of Direct

Subsidized Loans described in 34

CFR section 685.200(f), including

not receiving subsidized loans for

more than 150 percent of the

published length of the borrower’s

educational program (34 CFR

sections 685.200(a)(2)(i)(B), 685.200(f))

x

24.

Parents can receive a PLUS loan if

the conditions in items 2, 4, 5, 10,

and 14 above are met by the parent

and student (34 CFR section 685.200(c)(2))

x

25. Student is willing to repay the loan

(34 CFR section 674.9(e)) x

26. Students met FSEOG selection

criteria (34 CFR section 676.10) x

27.

Has submitted a completed

application (34 CFR section

686.11(a)(1)(i)) x

28.

Has signed an agreement to serve

(34 CFR sections 686.11(a)(1)(ii) and

668.12) x

29. Is enrolled in a TEACH Grant- x

3 ED issued a Dear Colleague Letter, dated February 17, 2016 (GEN-16-05), explaining additional requirements for

awarding Perkins Loans to undergraduate and graduate students. GEN-16-05 is available at

http://ifap.ed.gov/dpcletters/GEN1605.html.

http://ifap.ed.gov/dpcletters/GEN1605.html



Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

eligible institution in a TEACH

Grant-eligible program (34 CFR section 686.11(a)(1)(iii))

30.

Is completing coursework and other

requirements necessary to begin a

career in teaching or plans to

complete such coursework and

requirements prior to graduating (34 CFR section 686.11(a)(1)(iv))

x

31.

For the purposes of a student in a first

post-baccalaureate program, has not

completed the requirements for a

post-baccalaureate program as

described in 34 CFR section 686.2(d) (34 CFR section 668.32(c)(4)(ii))

x

32.

If first year of an undergraduate

program, has a final cumulative

secondary school GPA upon

graduation of at least a 3.25; a

cumulative GPA of at least 3.25

based on courses taken at the

institution through the most-recently

completed payment period; or a score

above the 75th percentile (for that

period the test was taken) on at least

one of the nationally-normed

standardized undergraduate

admissions test, which may not

include a placement test

(34 CFR sections 686.11(a)(1)(v)(A) and (E))

x

33.

If beyond the first year of an

undergraduate program, or a graduate

program, a cumulative GPA of at

least 3.25 based on courses taken at

the institution through the most-

recently completed payment period;

or a score above the 75th percentile

(for that period the test was taken) on

at least one of the nationally-normed

standardized undergraduate, graduate,

or post-baccalaureate admissions test,

which may not include a placement

test (34 CFR sections 686.11(a)(1)(v)(B) and (E))

x

34. If the student is a current or former

teacher or a retiree, the student is x



Requirements

PELL

IASG

FWS

FSEOG

TEACH

FPL

DIRECT

LOAN

HPSL/PCL/LDS

NSL/NFLP

SDS

applying for a grant to obtain a

master’s degree or pursuing

certification through a high-quality

alternative certification route (34

CFR section 686.11(b)(2))

35.

The student is eligible if he or she

was less than 24 years old when the

covered parent or guardian died, or if

24 years old and over, was enrolled at

an institution of higher education at

the time of the covered parent or guardian’s death (20 USC 1070h)

x



APPENDIX B


VERIFICATION REQUIREMENTS

FAFSA information Acceptable documentation

Income information for tax filers a. Adjusted Gross Income (AGI) b. U.S. Income Tax Paid c. Untaxed Portions of IRA Distributions d. Untaxed Portions of Pensions e. IRA Deductions and Payments f. Tax Exempt Interest Income g. Education Credits

For income information listed under items a. through g. for tax filers—

(1) 2015 tax account information of the tax filer that the Secretary has identified as having been obtained from the Internal Revenue Service (IRS) through the IRS Data Retrieval Tool

1 and that has not

been changed after the information was obtained from the IRS; or

(2) A transcript1 obtained from the IRS that lists 2015 tax account

information of the tax filer or (3) A transcript

1 that was obtained at no cost from the relevant taxing

authority of a U.S. Territory (Guam, American Samoa, the U.S. Virgin Islands) or Commonwealth (Puerto Rico and the Northern Mariana Islands), or a foreign central government that lists 2015 tax account information of the tax filer .

(34 CFR section 668.57(a))

Income information for tax filers with special circumstances

a. Adjusted Gross Income (AGI) b. U.S. Income Tax Paid c. Untaxed Portions of IRA Distributions d. Untaxed Portions of Pensions e. IRA Deductions and Payments f. Tax Exempt Interest Income g. Education Credits

(1) For a student or the parent(s) of a dependent student who filed a 2015 joint income tax return and whose income is used in the calculation of the applicant’s expected family contribution and who at the time the FAFSA was completed was separated, divorced, widowed, or married to someone other than the individual included on the 2015 joint income tax return— (a) A transcript

1 obtained from the IRS or other relevant taxing

authority that lists 2015 tax account information of the tax filer(s) ; and

(b) A copy of IRS Form W–22 for each source of 2015 employment

income received or an equivalent document. 2

(2) For an individual who is required to file a 2015 IRS income tax return and has been granted a filing extension by the IRS—

(a) A copy of IRS Form 4868, ‘‘Application for Automatic Extension of Time to File U.S. Individual Income Tax Return,’’ that the individual filed with the IRS for tax year 2015;

(b) If applicable, a copy of the IRS’s approval of an extension beyond the automatic 6-month extension if the individual requested an additional extension of the filing time for tax year 2015;

(c) A copy of IRS Form W–22 for each source of 2015 employment

income received or an equivalent document; 2

and (d) If self-employed, a signed statement certifying the amount of

AGI and U.S. income tax paid for tax year 2015.

Note: An institution may require that, after the income tax return is filed, an individual granted a filing extension submit tax information using the IRS Data Retrieval Tool

1 or by obtaining a transcript

1 from the IRS that lists 2015

tax account information . When an institution receives such information, it must be used to reverify the FAFSA information contained on the transcript

1.

(3) For an individual who was the victim of IRS tax-related identify



theft—

(a) A Tax Return DataBase View (TRDBV) transcript obtained from the IRS; and

(b) A statement signed and dated by the tax filer indicating that he or she was a victim of IRS tax-related identify theft and that the IRS has been made aware of the tax-related identify theft.

Note: Tax filers may inform the IRS of the tax-related identify theft and obtain a TRDBV transcript by calling the IRS’s Identify Protection Specialized Unit (IPSU) at 1-800-908-4490. Tax filers who cannot obtain a TRDBV transcript may instead submit another official IRS transcript or equivalent document provided by the IRS if it includes all of the income and tax information required to be verified. Unless the institution has reason to suspect the authenticity of the TRDBV transcript or an equivalent document provided by the IRS, a signature or stamp or any other validation from the IRS is not needed.

(3) (4) For an individual who filed an amended tax return with the IRS—

(a) A transcript obtained from the IRS that lists 2015 tax account information of the tax filer(s); and

(b) A signed copy of the IRS Form 1040X that was filed with the IRS.

Income information for nontax filers

a. Income earned from work

For an individual who has not filed and, under IRS or other relevant taxing authority rules (e.g., the Republic of the Marshall Islands, the Republic of Palau, the Federal States of Micronesia, a U.S. Territory or Commonwealth or a foreign central government), is not required to file a 2015 income tax return—

(1) A signed statement certifying—

(a) That the individual has not filed and is not required to file a 2015 income tax return ; and

(b) The sources of income earned from work and amount of income from each source for tax year 2015;

2) A copy of IRS Form W–22 for each source of 2015

employment income received or an equivalent document: 2

and

3) Confirmation of non-filing from the IRS or other relevant taxing authority dated on or after October 1, 2016.

(34 CFR section 668.57(a))

Number of Household Members A statement signed by the applicant and, if the applicant is a dependent student, by one of the applicant’s parents that lists the name and age of each household member for the 2017-2018 award year and the relationship of that household member to the applicant.

Note: Verification of number of household members is not required if —

For a dependent student, the household size reported on the ISIR is two and the parent is single, separated, divorced, or widowed, or the household size indicated on the ISIR is three if the parents are married or unmarried and living together; or



For an independent student, the household size indicated on the ISIR is one and the applicant is single, separated, divorced, or widowed, or the household size indicated on the ISIR is two if the applicant is married.

(34 CFR section 668.57(b))

Number in College (1) A statement signed by the applicant and, if the applicant is a dependent student, by one of the applicant’s parents listing the name and age of each household member who is or will be attending an eligible postsecondary educational institution as at least a half-time student in the 2018-2017 award year in a program that leads to a degree or certificate and the name of that educational institution.

(2) If an institution has reason to believe that the signed statement provided by the applicant regarding the number of household members enrolled in eligible postsecondary institutions is inaccurate, the institution must obtain documentation from each institution named by the applicant that the household member in question is, or will be, attending on at least a half-time basis unless—

(a) The applicant’s institution determines that such documentation is not available because the household member in question has not yet registered at the institution the household member plans to attend; or

(b) The institution has documentation indicating that the household member in question will be attending the same institution as the applicant.

Note: Verification of the number of household members in college is not required if the number in college indicated on the ISIR is “1.”

(34 CFR section 668.57(c))

(a)

High School Completion Status The applicants high school completion status when the applicant attends the institution in 2017-2018.

(1) High School Diploma

(a) A copy of the applicant’s high school diploma;

(b) A copy of the applicant’s final official high school transcript that shows the date when the diploma was awarded; or

(c) A copy of the “secondary school leaving certificate” (or other similar document) for students who completed secondary education in a foreign country and are unable to obtain a copy of their high school diploma or transcript.

Note: Institutions that have the expertise may evaluate foreign secondary school credentials to determine their equivalence to U.S. high school diplomas. Institutions may also use a foreign diploma evaluation service for this purpose.

(2) Recognized Equivalent of a High School Diploma



(a) General Educational Development (GED) Certificate or GED transcript;

(b) A State certificate or transcript received by a student after the student has passed a State-authorized examination (HiSET, TASC, or other State-authorized examination) that the State recognizes as the equivalent of a high school diploma;

(c) An academic transcript that indicates the student successfully completed at least a 2-year program that is acceptable for full credit toward a bachelor’s degree at any participating institution; or

(d) For a person who is seeking enrollment in an education program that leads to at least an associate degree or its equivalent and who excelled academically in high school but did not finish, documentation from the high school that the student excelled academically and documentation from the postsecondary institution that the student has met its written policies for admitting such students.

(3) Homeschool

(a) If the State where the student was homeschooled requires by law that such students obtain a secondary school completion credential for homeschool (other than a high school diploma or its recognized equivalent), a copy of that credential; or

(b) If State law does not require the credential noted in 3(a), a transcript or the equivalent signed by the student’s parent or guardian that lists the secondary school courses the student completed and documents the successful completion of a secondary school education in a homeschool setting.

Note: In cases where documentation of an applicant’s completion of a secondary school education is unavailable, e.g., the secondary school is closed and information is not available from another source, such as the local school district or a State Department of Education, or in the case of homeschooling, the parent(s)/guardian(s) who provided the homeschooling is deceased, an institution may accept alternative documentation to verify the applicant’s high school completion status. (e.g. DD Form 214 Certificate of Release or Discharge from Active Duty that indicates the individual is a high school graduate or equivalent as alternative documentation.) When documenting an applicant’s high school completion status, an institution may rely on documentation it has already collected for purposes other than the Title IV verification requirements if the documentation meets the criteria outlined above (e.g. high school transcripts maintained in the admissions office).

Verification of high school completion status is not required if the institution successfully verified and documented the applicant’s high school completion status for a prior award year.

(34 CFR sections 600.2 and 668.32(e)(1) and (e)(4))

Identity/Statement of Educational Purpose (1) An applicant must appear in person and present the following documentation to an institutionally authorized individual to verify the applicant’s identity—

(a) An unexpired valid government-issued photo identification such as, but not limited to, a driver’s license, non-driver’s identification card, other State-issued identification, or passport. The institution must maintain an annotated copy of the valid government-issued photo



identification that includes—

(i) The date the identification was presented; and

(ii) The name of the institutionally authorized individual who reviewed the identification; and

(b) A signed statement using the exact language as follows, except that the student’s identification number is optional if collected elsewhere on the same page as the statement:

Statement of Educational Purpose I certify that I _______________________(Print Student’s Name) am the individual signing this Statement of Educational Purpose and that the Federal student financial assistance I may receive will be used only for educational purposes and to pay the cost of attending _________(Name of Postsecondary Educational Institution) for 2017-2018. _____________________________________________ (Student’s Signature)

_____________________________________________ (Date)

____________________________________________ (Student’s ID Number) (2) If an institution determines that an applicant is unable to appear in

person to present a valid photo identification and execute the Statement of Educational Purpose, the applicant must provide the institution with— (a) A copy of an unexpired valid government-issued photo

identification such as, but not limited to, a driver’s license, non-driver’s identification card, other State-issued identification, or passport that is acknowledged in a notary statement or that is presented to a notary; and

(b) An original notarized statement signed by the applicant using the exact language as follows, except that the student’s identification number is optional if collected elsewhere on the same page as the statement:

Statement of Educational Purpose

I certify that I _______________________(Print Student’s Name) am the individual signing this Statement of Educational Purpose and that the Federal student financial assistance I may receive will be used only for educational purposes and to pay the cost of attending _________(Name of Postsecondary Educational Institution) for 2017-2018. ____________________________________________ (Student’s Signature) _____________________________________________ (Date)



____________________________________________ (Student’s ID Number) (34 CFR section 668.57(d))

1 An institution may accept a copy of the original 2015 income tax return for tax filers who are—

(a) Consistent with guidance that the Secretary may provide following the period after the IRS processes 2015 income tax

returns, unable to use the IRS Data Retrieval Tool or obtain a transcript from the IRS.

(b) Unable to obtain a transcript at no cost from the taxing authority of a U.S. Territory (Guam, American Samoa, the U.S.

Virgin Islands) or Commonwealth (Puerto Rico and the Northern Mariana Islands), or a foreign central government

that lists tax account information of the tax filer ;

The copy of the 2015 income tax return must include the signature of the tax filer or of one of the filers of a joint income tax

return or the signed, stamped, typed, or printed name and address of the preparer of the income tax return and the preparer’s

Social Security Number, Employer Identification Number, or Preparer Tax Identification Number. For a tax filer who filed an

income tax return other than an IRS form, such as a foreign or Puerto Rican tax form, the institution must sue the income

information (converted to U.S. dollars) from the lines of that form that correspond most closely to the income information

reported on a U.S. income tax return.

An individual who did not return a copy of his or her 2015 tax account information and that information cannot be located by the

IRS or other relevant taxing authority, must submit to the institution—

(a) Copies of all IRS Form W-2s or an equivalent document;

(b) Documentation from the IRS or other relevant taxing authority that indicates the individual’s 2015 tax account

information cannot be located; and

(c) A signed statement that indicates that the individual did not retain a copy of his or her 2015 tax account information.

2 An individual who is required to submit an IRS Form W–2 or an equivalent document but did not maintain his or her copy

should request a duplicate copy from the employer who issued the original or from the government agency that issued the

equivalent document. If the individual is unable to obtain a duplicate W–2 or an equivalent document in a timely manner, the

institution may permit that individual to provide a signed statement, in accordance with 34 CFR section 668.57(a)(6), that

includes —

(a) The amount of income earned from work,

(b) The source of that income, and

(c) The reason that the IRS Form W–2 and an equivalent document is not available in a timely manner.

student financial assistance programs department of

Documents